IRS Notice 2023-11 provides temporary relief for foreign financial institutions to provide U.S. taxpayer identification numbers for preexisting accounts.
Continue Reading IRS Temporary Relief for Foreign Financial Institutions Required to Report U.S. Taxpayer Identification Numbers Under FATCA: Potential Implications for ‘Accidental Americans’
The proposed regulations demonstrate that the IRS is taking a proactive approach in addressing the APA challenges to its method for identifying listed transactions. The IRS makes clear that it will continue to aggressively pursue syndicated conservation easement transactions.
Continue Reading Responding to Recent Taxpayer Victories, IRS Issues Proposed Regulations Identifying Syndicated Conservation Easement Transactions as Listed Transactions
The Inflation Reduction Act of 2022 (IRA) grants a number of tax credits and tax deductions for taxpayers for the purpose of inducing energy efficiency steps. One tax benefit the
Continue Reading Inflation Reduction Act Provides Tax Benefit for Exempt Organizations
On Aug. 29, the IRS released a new section to the Internal Revenue Manual (IRM), 20.1.1.3.3.2.2, providing penalty relief for certain taxpayers filing 2019 and 2020 returns in response to
Continue Reading IRS Revisions to Internal Revenue Manual Clarify Who Is Eligible for Late Filing Penalty Relief
On Aug. 24, 2022, the IRS issued Notice 2022-36, which provides penalty relief to taxpayers for certain late-filed 2019 and 2020 tax returns and information returns, but this relief
Continue Reading The IRS Grants Penalty Relief for 2019 and 2020, But…
Equine industry assets that could be subject to government seizure include real estate, equipment, and the horses themselves, although horses valued below $10,090 are exempt from levy.
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Continue Reading Your Horse May Be Subject to IRS Seizure
This GT Alert provides a high-level summary of key tax provisions of the Inflation Reduction Act, which President Biden signed into law on Aug. 16, 2022.
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Continue Reading The Inflation Reduction Act – Key Tax Considerations
In a rare change of position, on June 2, 2022, the district court granted the government’s motion in CIC Services, holding the IRS was not required to return the
Continue Reading District Court Grants Government’s Motion for Reconsideration in CIC Services: IRS Not Required to Return Disclosure Documents Obtained Under Notice 2016-66
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