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Trump Administration Opens the Door to Double-Tax-Rate Penalty on Foreign Companies and Individuals

As part of its “America First Trade Policy,” the White House is exploring an arcane IRS provision that allows the United States to double the tax rates of foreign companies and individuals....more

The Gift and Estate Tax Exclusion: Lock It In or Let it Ride?

The Gift and Estate Tax Exclusion is currently scheduled to be reduced by approximately 50% in about 13 months. Without action from Congress, on January 1, 2026, the Exclusion will go from almost $14 million to about $7...more

IRS Starts Asking Direct Questions to Taxpayers on Their ERC Claims

As previously reported by Miller Canfield, unscrupulous promotors caused many taxpayers to file claims for the Employee Retention Credit even when they did not qualify. As a result, the IRS views claims for this credit with...more

Can Legislative History Restore a Repealed IRC Provision?

Altria Group, Inc. v. United States, a federal income tax case pending in federal district court in Virginia, shows the importance of laying groundwork for litigation long before a complaint is filed. At issue is a difficult...more

Amount Realized and Cost Basis in a Property Transaction With Hard-to-Value Property

In Private Letter Ruling 202352011 (December 30, 2023), the taxpayer asked the IRS to determine the amount that it will realize in a property transaction. The taxpayer will receive the property in an arm’s length exchange...more

IRS Expands ERC Voluntary Disclosure Program to Employers Who Already Received Their Checks

As previously reported by Miller Canfield, in October 2023 the IRS launched a withdrawal program for Employee Retention Credit (ERC) claims for employers who now doubt the validity of their claim. Unfortunately, employers who...more

IRS Announces Denials of Employee Retention Credit

As described in our October 24 article “IRS Offers Forgiveness for Erroneous Employee Retention Credit Claims” the IRS has increased scrutiny on claims for the Employee Retention Credit (“ERC”). The IRS halted processing...more

OSHA Recommendations on COVID Are Not Enough to Qualify a Business for the Employee Retention Credit

The IRS recently issued guidance explaining that OSHA communications regarding COVID-19 precautions alone do not allow employers to qualify for the Employee Retention Credit (“ERC”). Other than some start-up businesses,...more

In a Pending Research Tax Credit Case the IRS Fails to Follow Regulatory Language

The stream of cases challenging disallowance of research tax credits continues in the Tax Court with Phoenix Design Group, Inc. v. Commissioner. The taxpayer in Phoenix Design designs mechanical, electrical, and plumbing...more

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