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 U.S. Department of the Treasury announced initial wage and apprenticeship guidance under the Inflation Reduction Act of 2022 (IRA) that applies to taxpayers in order to increase available credit
Continue Reading Treasury Announces Initial Guidance on the Inflation Reduction Act’s Labor Requirements for Renewable Energy Tax Credits and Incentives
In Green Valley Investors, LLC, Et Al., Bobby A. Branch, Tax Matters Partner, v. Commissioner, the Tax Court on Nov. 9 abated Internal Revenue Code (I.R.C.) § 6662A penalties
Continue Reading U.S. Tax Court Invalidates Conservation Easement Notice, Abates Reportable Transaction Penalty for Failure to Comply with Administrative Procedure Act
The U.S. Department of the Treasury’s Community Development Financial Institutions Fund (CDFI Fund) on Oct. 28 announced $5 billion in New Markets Tax Credit (NMTC) awards with the goal of
Continue Reading U.S. Treasury Announces $5 Billion Allocation of New Markets Tax Credit Awards
The Commonwealth Court of Pennsylvania recently held in Online Merchants Guild v. Hassell that the Pennsylvania Department of Revenue failed to provide sufficient evidence that non-Pennsylvania businesses selling merchandise through
On Oct. 19, 2022, the IRS issued a warning to employers about what it calls “third parties” who promote claiming large employment tax refunds from improperly claiming the Employee Retention
Continue Reading IRS Warns Employers About ‘Third Parties’ Falsely Claiming Tax Refunds from ERC
A Maryland circuit court judge has struck down Maryland’s first-in-the-nation digital advertising tax. On Oct. 17, 2021, ruling from the bench, the judge held that the law violates the federal
Continue Reading Maryland’s Digital Advertising Tax Defeated
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 Oct. 3, 2022, the U.S. Supreme Court granted certiorari in In Re Grand Jury. On appeal from the Ninth Circuit, In Re Grand Jury considers whether the attorney-client
Continue Reading U.S. Supreme Court Grants Certiorari in Case Involving Application of Attorney-Client Privilege to Dual-Purpose Communications with Tax Attorneys