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
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
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
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
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
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
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
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
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
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
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
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
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
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
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
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
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
10/5/2022
/ Administrative Law Judge (ALJ) ,
Exports ,
Franchise Taxes ,
Income Taxes ,
Internal Revenue Code (IRC) ,
IRS ,
Sales Tax ,
State Taxes ,
Tax Liability ,
Tax Planning ,
Tax Returns
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
8/31/2022
/ Continuing Legal Education ,
Cross-Border ,
Cryptocurrency ,
Enforcement ,
Foreign Derived Intangible Income (FDII) ,
GILTI tax ,
Income Taxes ,
International Tax Issues ,
IRS ,
Multinationals ,
Tax Liability ,
Tax Penalties ,
Tax Planning ,
Tax Reform ,
Transfer Pricing ,
Webinars
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
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 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
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
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
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
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