Tax Practice Shareholder Pallav Raghuvanshi is quoted in an April 29 Thomson Reuters Checkpoint article titled “The Long Read: Catching Up With Crypto.”
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Continue Reading Pallav Raghuvanshi Quoted in Thomson Reuters Article, ‘The Long Read: Catching Up With Crypto’
Taxpayers and material advisors with current disclosure requirements or who have paid penalties for failing to disclose reportable transactions may wish to consult with their tax advisors about their ongoing
Continue Reading The Saga Continues in CIC Services v. IRS: Government Moves to Prevent IRS from Returning Disclosure Documents Obtained from Nonparties Under Notice 2016-66
In a bipartisan effort to pass new legislation to extend and provide for increased reporting under the Qualified Opportunity Zone (QOZ) Program, on April 7, 2022, members of Congress introduced
Continue Reading Bipartisan Proposed Legislation Released for Qualified Opportunity Zone Investments
The Fourth Circuit in Cook v. United States held that federal tax penalty assessments and the payments the debtor made were not voidable fraudulent transfers that generally allow debtors to
Continue Reading 4th Circuit Holds Tax Penalty Obligations Are Not Voidable Fraudulent Transfers
In CIC Services, LLC v. IRS,1 the U.S. District Court for the Eastern District of Tennessee invalidated Notice 2016-66 for failing to comply with the Administrative Procedure Act
Continue Reading Court Invalidates IRS Notice 2016-66 on Micro-Captive Transactions, the Second Time an IRS Notice Was Vacated This Month
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On 16 February 2022, the Netherlands and Colombia signed a tax treaty for the elimination of double taxation and the prevention of tax evasion and avoidance. The Treaty prevents double
Continue Reading The Netherlands and Colombia Have Signed a Tax Treaty
On March 3, 2022, the U.S. Court of Appeals for the Sixth Circuit ruled in Mann Construction, Inc. v. U.S.1 the IRS must follow the Administrative Procedures Act (APA)
Continue Reading 6th Circuit Rules IRS Must Follow Administrative Procedures Act in ‘Listing’ Transactions, Raising Questions on Extent of Case’s Application
Greenberg Traurig Shareholder James O. Lang was named a “Top 25 OZ Attorney 2021” by Opportunity Zone Magazine. James Lang’s practice is focused on tax incentive programs, Qualified Opportunity
Continue Reading James O. Lang Named a ‘Top 25 OZ Attorney’ by Opportunity Zone Magazine
On Feb. 15, 2022, the IRS announced revisions to Form 14457, the Voluntary Disclosure Practice Preclearance Request and Application. The longstanding Voluntary Disclosure Practice is a way for taxpayers who
Continue Reading IRS Announces Revisions to the Application Form for Voluntary Disclosures with New Provisions for Cryptocurrency, Employment Tax, and Estate, Gift and Generation-Skipping Transfer Tax
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The IRS has not issued any clear guidance on the taxation of staking rewards. In 2014, the IRS issued Notice 2014-21, which provides that cryptocurrency is treated as property for
Continue Reading A Recent Court Case Leaves Many Speculating on the Taxation of Staking Rewards