Two recent tax court cases paint an ominous picture for professionals and investors who participated in listed syndicated conservation easement transactions. Coming on the heels of the Fisher conviction and his lengthy...more
3/7/2024
/ Appraisal ,
Charitable Donations ,
Conservation Easements ,
Fair Market Value ,
Income Taxes ,
Internal Revenue Code (IRC) ,
IRS ,
Tax Court ,
Tax Deductions ,
Tax Fraud ,
Tax Liability ,
Tax Planning
Following our initial reaction to the Internal Revenue Service's strategic operating plan to spend $80B in funding allocated from the Inflation Reduction Act, Polsinelli’s Tax attorneys continue to monitor the IRS’ compliance...more
After much anticipation, the IRS has finally announced a strategic operating plan to spend the nearly $80 billion in funds that it was allocated through the Inflation Reduction Act. Since this bill was signed, the new IRS...more
4/18/2023
/ Enforcement Actions ,
Federal Taxes ,
High Net-Worth ,
Income Taxes ,
Inflation Reduction Act (IRA) ,
IRS ,
Pass-Through Entities ,
Tax Audits ,
Tax Liability ,
Tax Planning ,
Tax Returns
Less than a month after the heavily followed Green Valley Investors, LLC, et al., decision, the IRS issued proposed regulations to identify certain syndicated conservation easement transactions as listed transactions – this...more
12/21/2022
/ Administrative Procedure Act ,
Comment Period ,
Conservation Easements ,
Income Taxes ,
IRS ,
Proposed Regulation ,
Rulemaking Process ,
Tax Court ,
Tax Reform ,
Tax Shelters ,
Transaction Reporting
On November 9, 2022, in a 15-2 decision, the Tax Court held that the IRS improperly issued Notice 2017-10 in Green Valley Investors, LLC, et al. v. Commissioner of Internal Revenue, 159 T.C. No. 5. The Notice designated...more
11/16/2022
/ Administrative Procedure Act ,
Charitable Deductions ,
Conservation Easements ,
Income Taxes ,
Internal Revenue Code (IRC) ,
Investment ,
IRS ,
Partnerships ,
Tax Avoidance ,
Tax Court ,
Tax Deductions ,
Tax Penalties ,
Tax Planning
The IRS just announced, in releasing Notice 22-36, that it will be automatically issuing an estimated $1.2 billion in refunds or credits related to failure to file penalties assessed against taxpayers on a broad range of 2019...more
Overview -
Over the past year, several tax law changes have been proposed by the Biden administration and, in September 2021, draft legislative language was circulated, which set forth proposed changes to the Internal...more
12/1/2021
/ Biden Administration ,
Capital Gains Tax ,
Corporate Taxes ,
Foreign Derived Intangible Income (FDII) ,
Foreign Tax Credits ,
GILTI tax ,
High Net-Worth ,
Income Taxes ,
Net Investment Income ,
Pending Legislation ,
SALT ,
Share Buybacks ,
Tax Deductions ,
Tax Liability ,
Tax Planning ,
Tax Reform ,
Wash Sale Rules
In April 2021, President Biden announced the “American Families Plan,” which included some significant tax law changes. On May 28, 2021, the United State Department of Treasury issued a report entitled “General Explanation of...more
9/22/2021
/ Biden Administration ,
C-Corporation ,
Capital Gains Tax ,
Carried Interest Tax Rates ,
Corporate Taxes ,
High Net-Worth ,
Income Taxes ,
Internal Revenue Code (IRC) ,
Like Kind Exchanges ,
Proposed Legislation ,
Tax Deductions ,
Tax Planning ,
Tax Reform ,
Ways and Means Committee
On April 28, 2021, the White House issued a fact sheet which set forth some additional details on the tax increase proposals contained in President Biden’s “American Families Plan.” ...more
On December 22, 2017, President Trump signed into law what’s known as the Tax Cuts and Jobs Act. The Act, also sometimes referred to as H.R. 1, contains massive changes to existing tax law the likes of which have not been...more
12/28/2017
/ Alternative Minimum Tax ,
Corporate Taxes ,
Income Taxes ,
International Tax Issues ,
New Legislation ,
Tax Cuts and Jobs Act ,
Tax Deductions ,
Tax Exemptions ,
Tax Rates ,
Tax Reform ,
Trump Administration
The Senate passed a version of the Tax Cuts and Jobs Act that differs significantly from the House-passed bill but still contains several similar proposals that lower individual and business tax rates, completely revamp the...more
12/5/2017
/ Alternative Minimum Tax ,
Business Taxes ,
Corporate Taxes ,
Income Taxes ,
International Tax Issues ,
Legislative Agendas ,
Net Operating Losses ,
Pass-Through Entities ,
Proposed Legislation ,
Tax Deductions ,
Tax Rates ,
Tax Reform ,
Trump Administration
The Senate Finance Committee Chairman’s Mark for the “Tax Cuts and Jobs Act,” released Nov. 9, describes in detail the Senate tax bill and is significantly different than the House bill, as it currently stands....more
11/14/2017
/ Alternative Minimum Tax ,
Business Taxes ,
Corporate Taxes ,
Estate Tax ,
Income Taxes ,
International Tax Issues ,
Legislative Agendas ,
Mortgage Interest ,
Pass-Through Entities ,
Proposed Legislation ,
Tax Deductions ,
Tax Rates ,
Tax Reform ,
Trump Administration
This update to our Tax Alert on Nov. 2nd describes additional key provisions in the “Tax Cuts and Jobs Act” (H.R. 1), released by the Chairman of the House Ways and Means Committee on Nov. 2nd, as well as the Chairman’s...more
11/8/2017
/ Compensation & Benefits ,
Deferred Compensation ,
Income Taxes ,
Internal Revenue Code (IRC) ,
Legislative Agendas ,
Repeal ,
Section 409A ,
Tax Code ,
Tax Planning ,
Tax Reform ,
Trump Administration
On November 2, 2017, the House Ways and Means Committee released the “Tax Cuts and Jobs Act” (H.R. 1). Key elements include reducing the tax rate on corporations to 20%, and reducing the tax rate paid on income earned by...more
11/3/2017
/ 401k ,
Alternative Minimum Tax ,
Business Taxes ,
Charitable Donations ,
Child Tax Credit ,
Contribution Limits ,
Corporate Taxes ,
Employee Benefits ,
Estate Tax ,
Income Taxes ,
Local Taxes ,
Mortgage Interest ,
Pass-Through Entities ,
Retirement Plan ,
State and Local Government ,
State Taxes ,
Tax Deductions ,
Tax Rates ,
Tax Reform ,
Trump Administration
Comprehensive tax reform that lowers business and individual tax rates, streamlines the tax code, and allows U.S. businesses to become more competitive in the global economy are among the top priorities of the Trump...more
Recent amendments to the Internal Revenue Code of 1986 (the Code) have significantly expanded the opportunity for tax savings under Section 1202. Section 1202, which was originally added to the Code in 1993, provides relief...more
6/29/2016
/ Alternative Minimum Tax ,
Capital Gains ,
Gain Exclusion ,
Income Taxes ,
Internal Revenue Code (IRC) ,
IRS ,
Protecting Americans from Tax Hikes (PATH) Act ,
Qualified Small Business Stock ,
Small Business ,
Stock Purchase Agreement ,
Stocks
On Tuesday, April 27, 2015, Missouri Governor Jay Nixon signed House Bill 384, which creates a Tax Amnesty Program for taxes administered by the Missouri Department of Revenue. This includes state income taxes, franchise...more
In this issue, we address important new Missouri tax changes that were passed on May 6, 2014 after the Missouri Legislature overruled Governor Jay Nixon's veto. The legislation modifies the individual income tax rate table by...more
After much contention,Congress passed the American Taxpayer Relief Act of 2012, and President Obama signed the legislation on January 2, 2013. The Act avoids automatic sunset provisions that were scheduled to take effect...more
1/22/2013
/ Alternative Minimum Tax ,
American Taxpayer Relief Act ,
Bush-Era Tax Cuts ,
Business Taxes ,
Capital Gains ,
Dividends ,
Energy Tax Incentives ,
Estate Tax ,
FICA Taxes ,
Fiscal Cliff ,
Income Taxes ,
Itemized Deductions ,
Tax Rates