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’
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