Recent taxpayer experiences suggest that IRS agents are becoming more aggressive in denying taxpayer claims of research and development tax credits through narrow construction of the so-called “substantially all” test of Code...more
At the beginning of, 2021, Congress slipped the so-called Corporate Transparency Act “CTA”), a new business reporting obligation, into the National Defense Authorization Act of 2021. Among other things, the CTA requires every...more
Delaware and several western or mid-western states, including Nevada which has been somewhat of a pioneer in the development of LLC law, have enacted business entity rules pursuant to which an LLC organized in that...more
The Internal Revenue Service has increased its scrutiny of inter-company pricing practices of taxpayers with foreign affiliates and has provided agents conducting audits with standard language requesting information about...more
The Internal Revenue Service has warned tax professionals, as the 2016 filing season begins, to be alert to a new email scam by cybercriminals posing as clients soliciting their services. The scam is a variation of a...more