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Audits Internal Revenue Code (IRC)

IR Global

Accountants Advising on Ownership Structure

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An Accountant based in Atlanta, Georgia provided valuable advice to a new Client who was starting a kitchen design business with a business partner....more

Husch Blackwell LLP

Impending IRS Workforce Cuts Mean Taxpayers Should Act Now to Resolve IRS Issues

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The New York Times reported on March 4, 2025, that the Trump administration is aiming to cut half of the Internal Revenue Service’s workforce by the end of the year. The cuts are reportedly across all divisions of the IRS,...more

Allen Barron, Inc.

The Taxpayer Bill of Rights - 10 Essential Rights for U.S. Taxpayers

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Are you aware of the Taxpayer Bill of Rights?  We are reminded, especially during tax season, that taxpayers have 10 essential rights when dealing with the Internal Revenue Service. The IRS expects its employees to understand...more

Allen Barron, Inc.

The Appeal of an IRS Audit is Based Upon the Audit's Examination File

Allen Barron, Inc. on

Did you know the appeal of an IRS audit is based upon the IRS examination file record of the audit itself? When the IRS produces its "Notice of Determination" at the end of an audit, a very important door closes: the ability...more

Holland & Hart LLP

the buzz: Cannabis News & Policy Update | February 2025 Special Tax Edition

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Welcome to the buzz: Special Tax Edition. April 15 is just over two months away. This Special Tax Edition includes practical considerations to help you prepare for tax filing season, including: A former DOJ attorney...more

Williams Mullen

[Event] 2025 Winter Tax Forum - February 6th, Richmond, VA

Williams Mullen on

Join Williams Mullen for our hybrid 2025 Winter Tax Forum on Thursday, February 6th. Our speakers, Anna Derewenda, Kyle Wingfield, Kevin Bender, and Patrick Carr will provide an update on the following: - New Basis...more

Husch Blackwell LLP

Cannabis Trends in 2025

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2024 was a primarily lean and flat year for the U.S. cannabis industry. The state-legal cannabis industry has been volatile from its inception, and 2024 represented a year of winnowing with many cannabis businesses failing....more

Lippes Mathias LLP

Know Your Rights: Managing Exposure During Audits Through Legal Representation

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The 2022 Inflation Reduction Act (the “IRA”) allocated $80 billion in funding to the Internal Revenue Service (“IRS”), much of which was earmarked for increased enforcement efforts. After some starts and stops, that funding...more

King & Spalding

Senators Grassley and Warren Urge IRS to Increase Nonprofit Hospital Oversight Again

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On November 19, 2024, a bipartisan pair of senators, Sen. Charles E. Grassley (R-Id.) and Sen. Elizabeth Warren (D-Ma.) united again, a year after a similar letter, to urge the Internal Revenue Service (IRS) to increase...more

Holland & Knight LLP

Tribal GWE Proposed Regulations Are an Overdue Win for Indian Country

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The U.S. Department of the Treasury and IRS on Sept. 17, 2024, issued Proposed Regulations on the Tribal General Welfare Exclusion Act of 2014 (the Act). The Proposed Regulations are an overdue win for Indian country,...more

Foodman CPAs & Advisors

ERC Voluntary Disclosure Program Re-Opens

On 7/15/24, the IRS announced via Notice IR-2024-212 the re-opening of the ERC (Employee Retention Credit) Voluntary Disclosure Program which will end on 11/22/24. The first ERC Voluntary Disclosure Program ended in March...more

Fox Rothschild LLP

IRS Reopens Employee Retention Tax Credit Voluntary Disclosure Program

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The ERC is a legitimate, refundable tax credit designed to help businesses that continued to pay employees while they were shut down because of the COVID-19 pandemic or that experienced a significant decline in gross receipts...more

Holland & Knight LLP

IRS Targets Owners of Professional Sports Franchises Regarding Tax Reporting

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Basketball just wrapped up its season and hockey is in the last period of its season, but there is no summer vacation for the IRS Large Business and International (LB&I) division. The IRS recently announced a new enforcement...more

Farella Braun + Martel LLP

The IRS Is Targeting Partnership Transactions: Is Your Representative Ready?

Earlier this week, Treasury and the IRS issued guidance to halt the use of partnership rules in the Internal Revenue Code to engage in abusive basis-shifting transactions whereby tax basis is stripped from certain assets and...more

Greenberg Glusker LLP

Decoding Franchise Tax Board’s Hot Button Areas: Drops and Swaps and Post-Closing Refinancing

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Those of us in California who give advice regarding the structuring of IRC Section 1031 like-kind tax-deferred exchanges of real property are well aware that the California Franchise Tax Board (FTB) has an active program of...more

Rivkin Radler LLP

Missing the Tax Court’s 90-Day Deficiency Deadline – Now What?

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Over the years, I have observed there is only one thing that a taxpayer fears more than being notified by the IRS that their income tax return for a particular taxable year has been selected for audit, and that is being...more

Holland & Knight LLP

U.S. Tax Court Holds Bond Financing Costs Are Includible in LIHTC Basis

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A U.S. Tax Court decision entered on Feb. 20, 2024, in 23rd Chelsea Associates LLC v. Commissioner of Internal Revenue held that bond issuance and related financing costs incurred in connection with the development of a...more

Pillsbury Winthrop Shaw Pittman LLP

President Biden and Senators Support the Ramp Up in IRS Audits on Corporate Aircraft

President Biden announced that he will focus on ending tax breaks for corporate aircraft and “cracking down on corporate jet loopholes.” Several aviation and labor organizations, including the National Business Aviation...more

McDermott Will & Emery

TTB Ramps Up Tax Audits and Enforcement

McDermott Will & Emery on

The Alcohol and Tobacco Tax and Trade Bureau’s (TTB) Office of Field Operations is responsible for ensuring industry members comply with the Federal Alcohol Administration Act, the Internal Revenue Code and all related...more

Womble Bond Dickinson

IRS Continues Aggressive Oversight and Enforcement of Employee Retention Credits

Womble Bond Dickinson on

The Employee Retention Credit (ERC) is a refundable tax credit for businesses whose employees were impacted by the COVID-19 Pandemic. The provisions are set out in § 2301 of the CARES Act and § 3111 of the Internal Revenue...more

Pillsbury Winthrop Shaw Pittman LLP

IRS Ramps Up Audits on Corporate Aircraft Use for High-Net-Worth Individuals and Affiliated Entities

The Internal Revenue Service (IRS) is increasing audits on corporate aircraft use for high-net-worth individuals, large corporations and complex partnerships as part of its new initiative using Inflation Reduction Act funding...more

Eversheds Sutherland (US) LLP

IRS sees flight risk with corporate jets

On February 21, 2024, the IRS announced a new initiative to audit large corporate taxpayer use of corporate jets, as part of a larger initiative focused on tax compliance of large corporations and high-income taxpayers. The...more

Seward & Kissel LLP

For Fund Managers, Tax Court Ruling Sets Limited Partners Back “As Such”

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Memorandum to our Investment Management Clients and Friends - The United States Tax Court recently issued a ruling (the “Ruling”) pertaining to the possible exclusion of a limited partner’s distributive share of income...more

Davis Wright Tremaine LLP

IRS Delays SECURE 2.0 Roth Requirement for Catch-up Contributions Until 2026

On Friday, Aug. 25, 2023, the IRS announced a two-year reprieve for employers on the implementation of SECURE 2.0's requirement that catch-up contributions made by higher-income participants be designated as after-tax Roth...more

Bricker Graydon LLP

Why Time is of the Essence More than Ever in Correcting Retirement Plan Errors

Bricker Graydon LLP on

Errors in retirement plans happen even to the most well-intentioned plan sponsors. Several decades ago, the IRS published the first version of the Employee Plans Compliance Resolution Program (EPCRS), which outlines...more

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