Basketball just wrapped up its season and hockey is in the last period of its season, but there is no summer vacation for the IRS Large Business and International (LB&I) division. The IRS recently announced a new enforcement...more
The U.S. Tax Court recently held in SN Worthington Holdings LLC v. Commissioner, 162 T.C. No. 10 (2024), that the petitioning partnership had properly elected into the Bipartisan Budget Act of 2015 (BBA) procedures for the...more
6/3/2024
/ Audits ,
Bipartisan Budget Act ,
Corporate Taxes ,
Default ,
IRS ,
Jurisdiction ,
Partnerships ,
Tax Court ,
Tax Liability ,
Tax Returns ,
TEFRA
A U.S. Tax Court decision entered on Feb. 20, 2024, in 23rd Chelsea Associates LLC v. Commissioner of Internal Revenue held that bond issuance and related financing costs incurred in connection with the development of a...more
3/25/2024
/ Affordable Housing ,
Audits ,
Bond Financing ,
Construction Project ,
General Contractors ,
Housing Developers ,
Internal Revenue Code (IRC) ,
LIHTC ,
Low Income Housing ,
Real Estate Development ,
Tax Court ,
Tax-Exempt Bonds ,
Transaction Fees ,
Union Dues ,
Unions
The IRS announced a "sweeping" and "historic" enforcement effort focused on partnerships and is establishing a special group within its Large Business and International (LB&I) Division to focus exclusively on large and...more
With the IRS laser-focused on enforcement, many partnerships will find themselves subject to their first IRS audits under the new procedurally complex partnership audit rules. Under these rules, the default is that the...more
As Congress continues to deliberate the federal legalization of marijuana, the cannabis industry continues to face scrutiny from the IRS under Section 280E of the Internal Revenue Code (Code). Enacted in 1982 in response to a...more
4/23/2021
/ Audits ,
Business Expenses ,
Cannabis-Related Businesses (CRBs) ,
Controlled Substances ,
Controlled Substances Act ,
Hemp Related Businesses ,
Income Taxes ,
Internal Revenue Code (IRC) ,
IRS ,
Marijuana Related Businesses ,
Tax Court ,
Tax Deductions