Proceso constituyente en Colombia Parte II
Three courts - the Supreme Court, the Sixth Circuit, and the Tax Court - recently rejected administrative guidance in tax cases because the guidance was either wrong as applied, unnecessary, or inapplicable. The...more
Key Takeaways: ..In Boechler P.C., v. Commissioner (“Boechler”), the Supreme Court held that the thirty-day period to petition the Tax Court for review of an adverse determination by the IRS Appeals Office in a collection...more
On October 15, 2021, the Internal Revenue Service (the IRS or the Service) issued IR-2021-202 that describes the basis upon which taxpayers may rely on frequently asked questions (FAQs) to avoid certain penalties and...more
Employers that use an IRS-approved form 401(k) or profit sharing plan document are required to adopt updated IRS-approved adoption agreements no later than July 31, 2022. Most plan recordkeepers and other plan document...more
One of the most highly litigated issues in U.S. Tax Court is whether taxpayers are liable for certain penalties, additions to tax or additional amounts (each, a "penalty" and collectively, "penalties"). This should come as no...more
The IRS recently amended the rules applicable to hardship distributions from 401(k) and 403(b) plans. The new hardship distribution regulation relaxes some of the restrictions on the availability of hardship distributions...more
The Taxpayer First Act of 2019 ("TFA")1 has passed both chambers of Congress and will likely soon be signed into law by the President. The bill has a wide range of provisions affecting and modernizing the Internal Revenue...more
A recent case decided by the US Tax Court reminds us that when you litigate a case in Tax Court, what happened during the Internal Revenue Service (IRS) examination and Appeals bears very little relevance (if any) once you...more
As of January 1, 2019, the IRS stopped mailing lists of parent and subsidiary accounts to central organizations (group ruling holders) for verification and return. Central organizations with accounting periods ending June 30,...more
The IRS has recently taken affirmative steps towards assessing the Affordable Care Act (ACA) employer mandate penalties, which are set to begin before the end of 2017. The agency has updated its website with information...more