As promised, the U.S. Department of the Treasury (Treasury Department) and IRS on Dec. 27, 2022, issued guidance regarding the new corporate alternative minimum tax (CAMT) enacted as part of the Inflation Reduction Act (IRA)....more
This Holland & Knight alert discusses the intersection of President Joe Biden's proposed changes to the U.S. tax code, as announced in connection with his fiscal year (FY) 2023 budget, and work underway on the global stage...more
Since 2017, the Internal Revenue Service (IRS) Large Business and International Division (LB&I) has shifted its audit efforts to issue-based examinations, premised on strategically identified and prioritized areas of...more
By way of background, the budget that the president submits to Congress contains estimates of federal government income and spending for the upcoming fiscal year and also recommends funding levels for the federal government....more
6/4/2021
/ Appropriations Bill ,
Biden Administration ,
Corporate Taxes ,
Federal Budget ,
Green Book ,
Internal Revenue Code (IRC) ,
IRS ,
OECD ,
Proposed Legislation ,
Tax Reform ,
U.S. Treasury
The U.S. Treasury Inspector General for Tax Administration (TIGTA) recently audited the Internal Revenue Service's (IRS) programs to ensure compliance by expatriates with the provisions under Sections 877 and 877A of the...more
A U.S. shareholder of a foreign corporation generally is not subject to U.S. federal income tax on the income of the foreign corporation until the shareholder receives an actual distribution from the corporation. However,...more
Virtual currency transactions are now a prime focus of Internal Revenue Service (IRS) scrutiny. The IRS has numerous information-gathering tools to enforce its taxing power, including summons, artificial intelligence, data...more
12/4/2019
/ AICPA ,
Criminal Investigations ,
Cryptocurrency ,
Digital Currency ,
FBAR ,
Financial Transactions ,
FinCEN ,
Internal Revenue Code (IRC) ,
IRS ,
Popular ,
Reporting Requirements ,
Suspicious Activity Reports (SARs) ,
Tax Planning ,
Tax Returns ,
Virtual Currency ,
Voluntary Disclosure
In the "Relief Procedures for Certain Former Citizens" and accompanying FAQs, the Internal Revenue Service (IRS) provides a simplified pathway for certain non-compliant U.S. citizens who expatriated after March 18, 2010, to...more