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 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
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
Equine industry assets that could be subject to government seizure include real estate, equipment, and the horses themselves, although horses valued below $10,090 are exempt from levy.
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Continue Reading Your Horse May Be Subject to IRS Seizure
In CIC Services, LLC v. IRS,1 the U.S. District Court for the Eastern District of Tennessee invalidated Notice 2016-66 for failing to comply with the Administrative Procedure Act
Continue Reading Court Invalidates IRS Notice 2016-66 on Micro-Captive Transactions, the Second Time an IRS Notice Was Vacated This Month
The Internal Revenue Service (IRS) has extended the filing date for 2019 tax returns from April 15 to July 15. Several states also have extended filing deadlines and payment due
Continue Reading GT ALERT – States Revise 2019 Tax Filing Deadlines
The Tax Cuts and Jobs Act included a provision increasing taxes on tax-exempt organizations. New Internal Revenue Code Section 512(a)(7) required that tax-exempt organizations include in computing unrelated business taxable
Continue Reading 2019 Tax Act Effects on Tax-Exempt Organizations; Required Section 501(c)(4) Notices
Law360 recently published an article by Greenberg Traurig’s Barbara T. Kaplan, Michelle Ferreira, and Jennifer Vincent, titled “Prepare For Greater IRS Scrutiny On Conservation Easements.” While the Internal Revenue Service
Continue Reading Greenberg Traurig’s Barbara Kaplan, Michelle Ferreira, and Jennifer Vincent Featured in Law360
The Internal Revenue Service (IRS) publishes monthly the applicable federal rates (AFRs) under Internal Revenue Code (Code) Section 1274(d) and the Code Section 7520
Continue Reading Applicable Federal Rates and Code Section 7520 Rate for October 2019 – Downward Trend Accelerates