On April 7, 2023, the Second District of the California Court of Appeal published a landmark opinion on California property tax law that expands the tax-exempt status of intangible assets
Continue Reading California Court of Appeal Landmark Opinion Expands Intangible Asset Exemption from Property Tax Assessment
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
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 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 a major change in New York’s law on statutory residency, in a June 30 ruling in Obus v. New York State Tax Appeals Tribunal, the New York State
Continue Reading Greenberg Traurig Secures Win for Client in Obus v. New York State Tax Appeals Tribunal; Ruling is Major Change in New York Law on Statutory Residency
On May 13, 2022, in Reserve Mechanical Corporation v. Commissioner,[1] the U.S. Court of Appeals for the Tenth Circuit affirmed a Tax Court decision that a micro-captive insurance
Continue Reading Another Micro-Captive-Case Loss: 10th Circuit Affirms Tax Court Ruling in Reserve Medical Corp. v. Commissioner
In a rare change of position, on June 2, 2022, the district court granted the government’s motion in CIC Services, holding the IRS was not required to return the
Continue Reading District Court Grants Government’s Motion for Reconsideration in CIC Services: IRS Not Required to Return Disclosure Documents Obtained Under Notice 2016-66
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The IRS has not issued any clear guidance on the taxation of staking rewards. In 2014, the IRS issued Notice 2014-21, which provides that cryptocurrency is treated as property for
Continue Reading A Recent Court Case Leaves Many Speculating on the Taxation of Staking Rewards
On April 9, 2021, the IRS urged taxpayers who engage in micro-captive insurance arrangements to exit these transactions. This announcement follows an IRS victory in the U.S. Tax Court, which
Continue Reading IRS Wins Again on Micro-Captive Arrangements, Urges Taxpayers to Exit Transactions
Taxpayers are generally limited in their options for contesting state and local tax matters. The statutes imposing income, corporate, sales and property taxes prescribe the steps to be taken and