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
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
The U.S. Supreme Court has taken up the case of whether the Patient Protection and Affordable Care Act (ACA)’s individual mandate is unconstitutional. A decision on this issue is likely
Continue Reading Protecting Your Potential Tax Refund Should the Affordable Care Act’s Individual Mandate Be Determined Unconstitutional
Life changes as a result of COVID-19 may also have business considerations. One of those considerations is how changing residence will affect an individual’s taxes. That has become even more
Continue Reading Considerations When Changing Residency To Another State
In a unanimous decision written by Justice Neil Gorsuch (Rodriquez v. FDIC No 18-12690), the Supreme Court vacated a decision by the U.S. Court of Appeals for
Continue Reading Unanimous Supreme Court Restricts Application of Federal Common Law and Invalidates Bob Richards Doctrine in Tax Refund Disputes
On July 17, 2018, the Treasury Department issued new guidance for certain tax exempt organizations. The guidance pertains to the disclosure of the names and addresses of donors to organizations
Continue Reading IRS Disclosure Rules for Some Exempt Organizations Changed