The IRS is making good on its promise to step up enforcement on large partnerships that issue more than 100 annual K-1s and have more than $100 million in assets. As noted in this Latham Client Alert, the IRS’s renewed focus...more
The IRS’s simmering concern with pass-through entities is heating up, with IRA funds earmarked for increased personnel, AI, and other resources for partnership audits. ...more
The Tax Court’s decision setting aside IRS Notice 2017-10 for ignoring the APA’s notice and comment requirements has serious implications for other notices identifying listed transactions.
Key Points:
..Notice 2017-10...more
Economic aid legislation will likely result in increased scrutiny of certain industries, similar to investigations that followed relief efforts in the 2008 financial crisis.
Key Points:
..The CARES Act creates multiple...more
LB&I has announced compliance initiatives regarding the Section 965 Transition Tax, Repatriation via Foreign Triangular Reorganizations, and Virtual Currency transactions.
Key Points:
..The IRS continues its efforts to...more
The new tax law limits the deductibility of False Claims Act settlements and requires that settlement agreements identify the deductible “restitution” amount.
Settlements under the False Claims Act (FCA), which often...more