On Sept. 13, 2021, the U.S. House Ways and Means Committee announced a proposal to limit charitable deductions for conservation easement contributions made by partnerships and other passthrough entities. The
Continue Reading House Proposal Targets Charitable Deductions for Conservation Easements by Passthrough Entities
On July 28, 2021, the IRS secured two victories in court. The first win allows the IRS to impose an additional 35% penalty on an individual as the sole owner
Continue Reading IRS Secures Two Court Victories Involving Foreign Financial Activity
The IRS has published guidance stating that pre-2018 swaps among Bitcoin, Ether, and Litecoin are not eligible for 1031 tax-free exchange treatment. This means that investors who made swaps among
Continue Reading IRS Says No Tax-Free Exchange Treatment for Swaps of Bitcoin, Ether, and Litecoin
In February 2020, the IRS announced that it would step up efforts to contact high-income taxpayers (defined as earning $100,000 or more per year), who in prior years have failed
Continue Reading The IRS Announced a New Non-Filer Initiative Over a Year Ago – Now We See the Enforcement
Recent John Doe summonses show the IRS is expanding its use of those summonses to aggressively investigate potential tax evasion. Within the past week, the IRS has received authorization to
Continue Reading The IRS Continues Aggressive Use of John Doe Summonses to Investigate Tax Evasion Related to Use of Cryptocurrency, Offshore Service Providers
Taxpayers who lease or purchase aircraft face a myriad of tax issues, and aircraft can be a favorite target of both federal and state tax auditors. While the restrictions imposed
Continue Reading Non-Recourse Financing Can Imperil Tax Deductions: The Application of the Internal Revenue Code ‘At-Risk’ Rules to Aircraft Purchases
Taxpayers that have engaged in cryptocurrency transactions should be aware that the Internal Revenue Service is seeking customer records from cryptocurrency exchanges. The Department of Justice recently filed petitions in
Continue Reading IRS Actively Seeking Information Regarding Cryptocurrency Via John Doe Summonses
On Oct. 22, 2020, the IRS announced it is offering a second time-limited settlement initiative to certain taxpayers who participated in abusive micro-captive insurance transactions and who currently are under
Continue Reading Second Round of Micro-Captive Insurance Settlements Provides Stricter Terms
In July 2019 the IRS identified post offshore voluntary disclosure program (OVDP) compliance as a campaign. The purpose of the campaign is to pursue those OVDP participants who fail to
Continue Reading Your Offshore Voluntary Disclosure May Be Long Over but the IRS May Be Looking at Your Ongoing Tax Compliance
The Coronavirus Disease 2019 (COVID-19) pandemic caused the closure of Internal Revenue Service offices and service centers nationwide and the plummeting of new tax examinations. Although certain functions and ongoing
Continue Reading IRS Audit and Investigation Priorities Now That the IRS Is Back in Business