In recent years, the IRS has focused its attention and resources on large partnerships. In 2021, the agency launched an initial phase of its Large Partnership Compliance (LPC) program. Under this program, the IRS identified...more
On March 25, 2024, the IRS issued proposed regulations (REG-108761-22) which, if finalized, would identify certain CRATs as listed transactions. For those unaware of the listed transaction rules, such a designation would...more
We have previously spoken about monetized installment sales (“MISTs”) on Dollars & Sense. According to the IRS, these structures typically seek to defer gains associated with the sale of an appreciated asset through the use...more
For some time, the IRS has targeted fraudulent employee retention credit (“ERC”) claims. More recently, on December 21, 2023, the IRS issued guidance on a new voluntary disclosure program (the “ERC-VDP”) that the agency...more
United States citizens and residents are often not aware of the myriad of foreign information return filing obligations that exist under federal tax laws. For example, buried within the Code are reporting obligations...more
On September 8, 2023, the IRS issued a News Release suggesting that FBAR compliance investigations and audits would heat up in the near future. For those unfamiliar with FBARs, federal law requires United States persons to...more
10/11/2023
/ Failure-to-File ,
FBAR ,
Foreign Financial Accounts ,
Income Taxes ,
IRS ,
Offshore Funds ,
Penalties ,
Regulatory Requirements ,
Reporting Requirements ,
Tax Evasion ,
Tax Planning
Recent Government actions suggest that third-party promoters and potentially hundreds of taxpayers may be entering into abusive trust arrangements aimed at unlawfully eliminating or deferring federal income taxes....more
10/3/2023
/ Asset Management ,
Charitable Trusts ,
Criminal Conspiracy ,
Criminal Investigations ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Income Taxes ,
Indictments ,
Internal Revenue Code (IRC) ,
IRS ,
Tax Benefits ,
Tax Deferral ,
Tax Fraud ,
Tax Liability ,
Tax Shelters
For some time, the IRS has cautioned taxpayers about filing false or fraudulent ERC claims. More recently, on September 14, 2023, the IRS issued a News Release, IR-2023-169, indicating that it would no longer process ERC...more
On September 8, 2023, the IRS announced a multitude of compliance initiatives aimed at high-income taxpayers, partnerships, digital assets, FBARs and labor brokers. According to the announcement, the IRS has finalized its...more
For some time, promoters have shopped around an arrangement known as a “section 643(b) trust,” known alternatively as a “non-grantor, irrevocable, complex, discretionary, spendthrift trust.” On August 9, 2023, IRS Chief...more
Section 2301 of the CARES Act, as amended, permits employers to claim employee retention credits (“ERCs”) if they meet certain requirements. Under one of those requirements, an employer may claim an ERC if the employer’s...more
8/15/2023
/ Business Interruption ,
CARES Act ,
Coronavirus/COVID-19 ,
Employee Retention ,
Employees ,
Employer Liability Issues ,
IRS ,
Relief Measures ,
Supply Chain ,
Tax Credits ,
Tax Relief
Monetized installment sale transactions (“MISTs”) have been on the IRS’s radar for some time. On May 7, 2021, IRS Chief Counsel issued an advice memorandum, contending such transactions were “problematic” and “flawed”. And...more
Deadlines are important, particularly in federal tax law. Many taxpayers are aware, for example, of the significant penalties that the IRS may impose upon them for failure to timely file an income tax return or timely pay...more