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

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

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

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

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.

Continue reading the
Continue Reading The Inflation Reduction Act – Key Tax Considerations