On Dec. 21, 2023, the Internal Revenue Service (IRS) announced a new voluntary disclosure program (VDP) for taxpayers who have received an employee retention credit (ERC) refund for which they

Continue Reading IRS Announces Short-Term Voluntary Disclosure Program for Employee Retention Credits

California’s proposed legislation, Assembly Bill (AB) 886, aimed at imposing a tax on internet platforms for their use of digital journalism content, has been delayed in the Senate but may

Continue Reading California’s Proposed ‘Journalism Usage Fee’ Would Tax Internet Platforms for Linked News

In Polselli v. IRS, the Supreme Court was tasked with determining whether the IRS, pursuant to powers granted in Internal Revenue Code (IRC) section 7609(c)(2)(D)(i), is entitled to issue third-party summonses, without notice, for bank account records in which the taxpayer targeted by the summons does not have a legal interest.
Continue Reading Supreme Court Affirms IRS Power to Summons Bank Information Without Notice to Delinquent Taxpayer

On April 7, 2023, the Second District of the California Court of Appeal published a landmark opinion on California property tax law that expands the tax-exempt status of intangible assets

Continue Reading California Court of Appeal Landmark Opinion Expands Intangible Asset Exemption from Property Tax Assessment

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