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 4, the Internal Revenue Service issued Notice 2023-29 (the Notice), which describes certain rules the IRS intends to include in proposed regulations for qualifying for the energy community
Continue Reading IRS Issues Guidance for Developers, Investors Seeking to Qualify for Energy Community Bonus Credits Under Inflation Reduction Act
On April 10, 2023, the U.S. Treasury Department issued proposed regulations identifying certain micro-captive transactions as listed transactions or transactions of interest for purposes of the disclosure rules for taxpayers
Continue Reading IRS Proposed Regulations Identify Micro-Captive Transactions as Listed Transactions – Responding to CIC Services Decision
On April 3, 2023, the U.S. Tax Court ruled in Farhy v. Commissioner[1] that the IRS lacks statutory authority to assess Form 5471 penalties under I.R.C. § 6038(b)(1) or
Continue Reading IRS Lacks Statutory Authority to Assess International Information Return Penalties: U.S. Tax Court
The applicable penalty for the non-willful failure to file a foreign financial account is applied on a per-form basis, not a per-account basis, the U.S. Supreme Court decided Feb. 28
Continue Reading Non-Willful Failure to File FBAR Under BSA Should Be Penalized on a Per-Report Basis, Supreme Court Rules for Taxpayer Against IRS
The Internal Revenue Service issued Notice 2023-17 providing guidance on the Low-Income Communities Bonus Credit Program established under Internal Revenue Code Section 48(e) including environmental justice solar and wind capacity
Continue Reading IRS Releases Guidance on the Low-Income Communities Bonus Credit Program for Solar and Wind Facilities
The Internal Revenue Service issued Notice 2023-18 establishing a program to allocate $10 billion of credits for qualified investments in eligible qualifying advanced energy projects under Internal Revenue Code Section
Continue Reading IRS Establishes a Program to Allocate Credits to Qualifying Advanced Energy Projects
Please join Greenberg Traurig and Clayton Utz March 7 at 4:30 p.m. EST for a special webcast conversation with Rebecca Saint, Deputy Commissioner, Public Groups & International, Australian Tax
Continue Reading March 7 Webinar | A Conversation with the IRS and ATO
The Foreign Investment in Real Property Tax Act of 1980, as amended (FIRPTA), imposes tax on gain realized on disposition by nonresident alien individuals or foreign corporations (non-U.S. persons) of
Continue Reading IRS and Treasury Department Finalize Qualified Foreign Pension Funds Regulations
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’