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