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House Says No to Crypto Reporting Regs

On March 11, 2025, the United States House of Representatives passed a joint resolution to overturn a rule that the IRS had promulgated regarding “Gross Proceeds Reporting by Brokers That Regularly Provide Services...more

Treasury Issues Final Digital Asset Sourcing Regs and Proposed Cloud Transaction Sourcing Regs

On January 14, 2025, the Treasury Department and IRS issued final and proposed regulations on sourcing income from digital content and cloud transactions. Why is Source Important? While U.S. persons generally are...more

National Taxpayer Advocate’s Annual Report Highlights Issues Plaguing the IRS

In her annual report to Congress for 2024, National Taxpayer Advocate (“NTA”) Erin M. Collins identified the processing of Employee Retention Credits (“ERCs”), the administration of civil penalties, and changes to the...more

IRS Provides Temporary Relief on “Adequate Identification” Rules for Sales of Digital Assets

On December 31, 2024, the IRS issued Notice 2025-7, which provides alternative methods for adequately identifying digital assets held by a broker when digital assets are sold or exchanged for purposes of determining the basis...more

IRS to Ramp Up Tax Compliance Efforts In Connection with Wagering and Gambling

On September 30, 2024, the Treasury Inspector General for Tax Administration (“TIGTA”) issued a report evaluating the IRS’s enforcement efforts relating to taxpayers with gambling and wagering winnings....more

Eleventh Circuit Holds Willful FBAR Penalties Unconstitutional

In United States v. Schwarzbaum, the Eleventh Circuit recently held that certain penalties for failure to file FBARs violated the Excessive Fines Clause of the Eighth Amendment. The district court in this case had agreed...more

Tax Court Says No Collection Due Process Rights in Connection with Treaty Mutual Collection Assistance Request

In Ryckman v. Commissioner, the U.S. Tax Court tackled an issue of first impression: whether it has jurisdiction over a case challenging the denial by the Internal Revenue Service (“IRS”) of a collection due process (“CDP”)...more

Treasury and IRS Issue Final Digital Asset Reporting Regulations

The Treasury Department (“Treasury”) and Internal Revenue Service (“IRS”) recently published final regulations requiring brokers to file information returns and issue payee statements containing information regarding...more

Basket Contract Transactions are in the IRS’s Crosshairs

The Treasury Department and Internal Revenue Service are proposing regulations that would make so-called basket contract transactions as listed transactions under section 6011(a) of the Internal Revenue Code....more

Treasury Department and IRS Target Partnership Basis-Shifting Transactions

On June 17, 2024, the Treasury Department launched “a new regulatory initiative to close a major tax loophole exploited by large, complex partnerships.”[1] The loophole: partnership basis-shifting transactions....more

National Taxpayer Advocate Calls Out IRS on International Information Return Penalties

In a blog post on May 21, 2024, National Taxpayer Advocate Erin Collins called for the IRS to cease its systemic assessment of international information return penalties and for Congress to amend the Internal Revenue Code to...more

TITGA Reports on Status of IRS Digital Asset Monitoring and Compliance

The Treasury Inspector General for Tax Administration (“TITGA”) recently has released a report on the status of efforts by the Internal Revenue Service (“IRS”) to develop the digital asset monitoring and compliance strategy...more

Federal Income Tax Treatment of Contributions to Partnerships with Related Foreign Partners

No gain or loss generally is recognized on a transfer of property to a partnership in exchange for an interest in that partnership for federal income tax purposes (note that “partnership” here includes a limited liability...more

Malta Pension Funds

Amplifying its efforts to crack down on U.S. taxpayers’ use of Malta pension funds to attempt to achieve federal income tax savings, the IRS recently has issued proposed regulations identifying these funds as listed...more

Texas Tax Round Up | September 2022

Court Cases Sales and Use Tax Manufacturing Exemption Hegar v. Tex. Westmoreland Coal Co., Case 21-1007 (Tex. Sept. 30, 2022)—In this case, the Texas Supreme Court denied the Comptroller’s petition for review, leaving the...more

International Tax Withholding | Chapter 3 of the Internal Revenue Code

One of the more confusing areas of international tax law is determining when withholding is required. Getting it wrong can have dire consequences. Currently, U.S. international withholding provisions can be found in...more

Texas Tax Roundup | August 2022

Howdy folks, and welcome back to another action-packed edition of the Texas Tax Roundup! Let’s see what shocking developments in the realm of Texas tax that the month of August had in store!...more

[Webinar] The Freeman Law International Tax Symposium - October 20th - 21st, 9:00 am - 5:00 pm CST

Join leading tax experts from across the globe, as we discuss tax trends that are reshaping international taxation - AN EXPERIENCE UNLIKE ANY OTHER - Find yourself on the cutting-edge of international tax law, with...more

Moments in Tax History | Eisner v. Macomber | Income, an Origin Story

In Eisner v. Macomber, the U.S. Supreme Court ruled that for purposes of the Sixteenth Amendment, “income” was “a gain, a profit, something of exchangeable value proceeding from the property, severed from the capital however...more

OECD Proposes Rules for Intermediary Crypto-Asset Reporting, Due Diligence

On March 22, 2022, the Organization for Economic Cooperation and Development (“OECD”) issued proposed rules for the collection and exchange of information on transactions involving crypto-assets. The OECD intends for these...more

Foreign Gifts | When Do You Have To Report Them?

Foreign Gifts and IRS Reporting - U.S. persons who receive gifts or bequests from foreign persons beware—these gifts or bequests may need to be reported to the Internal Revenue Service (“IRS”). The consequences for failing...more

Federal Income Tax Characterization of Transactions Involving Computer Programs

The sale of a computer program—it seems simple. But, as illustrated by the Treasury Regulations’ computer program characterization rules, the issue of just what a sale of computer program is can become confusing fast....more

What Can the State of Texas Do to Collect State Taxes?

So, the Texas Comptroller of Public Accounts (“Comptroller”) says you owe state tax. If the deficiency determination hasn’t yet become final, you still may be able to challenge the underlying tax liability (for more on that,...more

Final Regulations on Stock Owned by Domestic Partnerships under Subpart F

On January 25, 2022, the Internal Revenue Services issued final regulations relating to the treatment of stock owned by domestic partnerships under certain provisions of subpart F of the Internal Revenue Code (“Subpart F”). ...more

ReDISCovering a Tax Classic: The Domestic International Sales Corporation

Created by Congress in 1971 as a tax incentive for domestic exporters of U.S.-made goods, the domestic international sales corporation (DISC) remains a viable tool for small-to-medium sized exporters to reduce their federal...more

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