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By: Randall P. Andreozzi, Esq. While we anxiously await Treasury Department guidance on cryptocurrency (See, TIGTA Report of September 24, 2020, “The Internal Revenue Service Can Improve Taxpayer Compliance for Virtual Currency Transactions”), events, good and bad, continue to arise that create tax planning and management opportunities for investors. Take, for example, Bitcoin’s recent dive from its high of some
By: Heather L. Marello, Esq. In a recent press release, IRS is again urging participants in abusive microcaptive insurance arrangements to cease participation in such transactions. This message comes after the Service’s recent win in the U.S. Tax Court in Caylor Land & Dev. v. Commissioner, T.C. Memo 2021-30 (2021). This win marks the fourth major victory in this area,
By: Heather L. Marello, Esq. I.R.C. § 6012(a)(2) imposes an income tax return filing requirement on “every corporation subject to taxation under subtitle A.” The Treasury Regulations clarify that a foreign corporation is not exempt from U.S. taxation if it is engaged in a U.S. trade or business, even if it has no effectively connected U.S. income or its income
By: Randall P. Andreozzi Congress last night passed COVID-relief legislation that included a much-anticipated provision that allows businesses to deduct qualifying expenses paid with forgiven Paycheck Protection Program (PPP) loans. IRS caused a stir earlier this year when it issued IRS Notice 2020-32 which told taxpayers that such otherwise-deductible expenses lose their character if they’re paid with forgiven PPP loans. The
By: Heather L. Marello and Kevin M. Murphy During a recent web conference, IRS Large Business and International Division Commissioner Douglas O’Donnell warned that IRS is gearing up to initiate hundreds of non-filer audits against high income individuals and those with related flow-through entities. The original announcement of this initiative came in July, 2019, when LB&I added high income non-filers
By: Randall P. Andreozzi, Esq. In 2016 the IRS issued Notice 2016-66, which identifies certain micro captive insurance transactions as potentially abusive. The Notice generally describes the abusive arrangement as one where owners of closely-held entities engage in a captive insurance arrangement that purports to ensure against certain risks associated with the business. The business pays “premiums” to the captive
By: Gary P. Bluestein Many accountants incorrectly assume that their communications with their tax clients are always privileged and confidential. Unfortunately, sometimes tax cases can cross over into potential criminal exposure for a client, and not knowing the scope and limitations of privilege can be devastating, both to the practitioner and to the client. Although there is limited privilege provided
By: Michael J. Tedesco, Esq. We find that accountants and taxpayers are often unfamiliar with certain aspects of the typical tax controversy (i.e. how a tax matter moves through assessment, Tax Court/Appeals and Collections). We have put together a series of articles moving through “The Lifecycle of a Tax Controversy”. What follows is the first part of what will be
By: John L. Marien On December 22, 2017, President Trump signed into law the Tax Cuts and Jobs Act. In light of the various tax cuts contained in the revisions to the Internal Revenue Code, Congress was compelled to formulate legislation that would recover some of the lost revenue. One provision aimed at recovering a portion of this revenue loss
By: Tiffany D. Bell, Esq. In 2010, Congress added to the anxiety of tax practitioners when it expanded the statute of limitations for the IRS to assess income taxes to six years when a taxpayer fails to include Form 8938 with his tax return. Taxpayers use Form 8938 to report to IRS foreign bank accounts and other specified foreign financial