Anyone with a pending U.S. Tax Court syndicated conservation easement matter who has received a settlement offer from the IRS should speak with an experienced tax attorney as soon as possible to understand the pros and cons of this offer before it expires. The IRS is serious about stopping fraudulently […]
The procedures are complex and the agency appears fairly rigid in it enforcement of the law. While the law restricting passport access for taxpayers with serious tax debts has been on the books for a while, until 2018, the IRS had refrained from enforcing it. Everything changed in February, when […]
The agency is combining forces with other federal law enforcement agencies as well as foreign counterparts in allied countries to uncover Russian elite sanction evasion and illegal asset movements. The IRS Criminal Investigation (CI or IRS-CI) is the part of the agency that investigates federal tax crimes. Its focused expertise […]
The agency’s efforts will focus on cryptocurrency-related failure to report income that may result in civil or criminal liability. Virtual currencies like Bitcoin, Ethereum or Litecoin exist digitally in intangible units called coins or tokens on decentralized ledgers. Despite the name “currency,” governments do not issue them. When people subject […]
The IRS publicized the holding of this closely watched appeal. In a highly anticipated May 2022 decision, the U.S. Court of Appeals for the 10th Circuit held that microcaptive insurance transactions can be abusive shams to avoid taxation, agreeing with the federal government’s long-held position. Today we consider the lessons of […]
The IRS has launched its new People First Initiative to ease tax-related pressure for some taxpayers through at least July 15, 2020. The IRS announced on March 25, 2020, that it will immediately provide relief to some American individuals and businesses mainly by temporarily freezing certain of its enforcement activities […]
Those who think they may be targets should consult a tax attorney now, before hearing from the IRS. During this economically and personally difficult year of 2020, the IRS surprisingly extended its iconic annual tax filing (and paying) deadline of April 15 until July 15. But in an apparent push […]
On behalf of Lawrence Brown If it sounds too good to be true, it might not be. Federal law allows taxpayers to take tax deductions for charitable donations of real estate easement rights to nonprofit entities that must then conserve the properties for the future. Congress recognizes these transactions as […]
Leaving the physical-presence test behind for the substantial-nexus text … The Internet has changed how we shop. We have come a long way from mail-order catalog shopping and while we still go to the main street store or the mall, many people prefer to shop online in the comfort of […]
The 10th Circuit in an important opinion has affirmed that microcaptive insurance schemes can be abusive when their purpose is to avoid taxation. In part 1 of this article, we explained microcaptive insurance arrangements and introduced Reserve Mechanical Corp. v. Commissioner of Internal Revenue (CIR), a May 2022 decision from […]