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Internal Revenue Service Taxable Income

The United States Internal Revenue Service is a bureau of the United States Department of the Treasury. The IRS is charged with collecting revenue and enforcing the Internal Revenue Code.  
Rivkin Radler LLP

Unconstitutionally Excessive FBAR Penalties? It Depends

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You may recall that earlier this year the IRS launched an initiative to pursue 125,000 “high-income, high-wealth” taxpayers who have not filed taxes since 2017. These were cases where the IRS received third party information...more

Foodman CPAs & Advisors

Reportaje de Broker de Activos Digitales

El 6/28/24, el Tesoro de los EE. UU. y el IRS emitieron regulaciones finales con una fecha de vigencia del 9/9/24 que requieren que los brokers de custodia reporten las ventas e intercambios de activos digitales a partir del...more

Foodman CPAs & Advisors

Digital Assets Broker Reporting

On 6/28/24, the U.S. Treasury and the IRS issued final regulations with an effective date of 9/9/24 requiring custodial brokers to report sales and exchanges of digital assets beginning in calendar year 2025. Meaning,...more

McGlinchey Stafford

Is a “Tip” Paid in Cryptocurrency a Tip for Employment Tax Purposes?

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Tips are in the news lately. It seems like political strategists on both sides of the aisle have concluded that excluding tips from taxable income is good for votes. One has to wonder if this political promise will go the way...more

Rivkin Radler LLP

When A Shareholder Loses Control of Their S Corporation

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If given their druthers, most transactional corporate attorneys would prefer to spend their day practicing “happy law,” by which they typically mean transactions that involve capital formation, mergers and acquisitions, joint...more

Rivkin Radler LLP

Taxing A Foreigner’s Sale of a Partnership Interest – Déjà Vu All Over Again

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There is no denying that many parts of the Code are complex and, in some cases, too obscure for many “laypersons” to comprehend. Over time, this reality spawned the need for advisers who are both knowledgeable and experienced...more

Allen Barron, Inc.

How Does the IRS Define Willfulness in Unreported or Under-reported Offshore Income

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How does the IRS define willfulness in unreported or under-reported offshore income?  What actions help determine whether a U.S. taxpayer's actions amount to "willful or non-willful" conduct?  Why should U.S. taxpayers be...more

Fox Rothschild LLP

Tax Court’s Decision on YA Global Investments Has Implications for Offshore Entities

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The Tax Court’s decision in YA Global Investments LP v. Commissioner in November sends a warning to the offshore banking, finance and equity investment industries: an offshore entity is engaged in U.S. trade or business when...more

Foodman CPAs & Advisors

Impuestos 2023: Lo Mejor Es Prepararse Ahora

La planificación fiscal le aplica a todos. El 1/22/24, el IRS le recordó a todos los contribuyentes que comenzaran a prepararse para presentar su declaración de impuestos federales sobre la renta. Planificar con anticipación...more

Foodman CPAs & Advisors

2023 Taxes: Best To Get Ready Now

Tax planning applies to everyone. On 1/22/24, IRS reminded all taxpayers to start getting ready to file their federal income tax return. Planning ahead can help taxpayers file an accurate return and avoid delays that can slow...more

Rivkin Radler LLP

Self-Employment Tax and the Limited Partner – Substance Over Form, or Something Else?

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Last week, the IRS announced “the start of a sweeping, historic effort to restore fairness in tax compliance by shifting more attention onto high-income earners, partnerships, large corporations and promoters abusing the...more

Vinson & Elkins LLP

IRS Releases Favorable Guidance on the Tax Treatment of Payments to REITs and MLPs for Subsurface Carbon Dioxide Storage

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Along with the broader market, real estate investment trusts (“REITs”) and publicly traded partnerships, frequently referred to as master limited partnerships (“MLPs”), have increasingly embraced the principles of...more

Bricker Graydon LLP

Is Your ESOP Ready for the Spotlight?

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Last week, the IRS announced it was increasing enforcement strategies aimed at Employee Stock Ownership Plans “ESOPs”. The IRS stated this new focus on ESOPs is part of the effort to ensure tax laws are applied fairly and...more

ArentFox Schiff

Self-Directed IRAs and the Prohibited Transaction Rules – Part 1

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Part 1: Permitted Investments and Compliance - The self-directed individual retirement account (IRA) is an increasingly popular option for an IRA account owner, especially those owners who have significant net worth and...more

McGlinchey Stafford

When Are My Rewards for Staking Cryptocurrency Taxed?

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The IRS recently released Revenue Ruling 2023-14, in which it addresses the tax treatment of cryptocurrency staking rewards. The IRS phases the issue as follows: If a taxpayer that uses a cash method of accounting...more

Rivkin Radler LLP

New York Examines Federal Income Tax Issues –Conformity and . . . Disclosure?

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Many years ago, New York revised its personal income tax law to achieve close conformity with the Federal system of income taxation. The stated purpose for the revision was to simplify tax return preparation, improve...more

Tucker Arensberg, P.C.

New IRS Program Could Change the Way Food & Beverage Industry Tips are Reported - But First...the IRS Wants to Hear From You

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Get ready for a game-changer in tip reporting compliance! The Treasury Department and IRS have just announced the proposed launch of the Service Industry Tip Compliance Agreement (SITCA) program. SITCA is a voluntary...more

McGlinchey Stafford

IRS Proposes New Program for Service Industry Employers to Avoid Paying Tax on Employee Unreported Tips

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The Internal Revenue Service (IRS) is proposing a new voluntary program, referred to as the Service Industry Tip Compliance Agreement (SITCA) program, for employers in service industries to avoid paying the employer’s share...more

Rivkin Radler LLP

Generating Tax Losses as a Hobby

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Every now and then, some well-meaning colleague will ask how I spend my free time. I usually pause before responding – to gather my thoughts – which prompts them to restate their question with what they believe is greater...more

Paul Hastings LLP

IRS Delays Implementation of $600 Reporting Threshold for Forms 1099-K

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On Friday, December 23, 2022 the Internal Revenue Service provided a late Holiday Gift to payment card processors, third party settlement organizations, and potentially people who sold goods or services in excess of $600 in...more

Rivkin Radler LLP

Transacting With One’s Business – Keep It Arm’s Length

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Don’t Be Unreasonable- Much has been written of late regarding the payment by a business of various personal expenses incurred by its owner or certain key employees. The payment of an owner’s personal expenses appears to...more

Cadwalader, Wickersham & Taft LLP

Staking Rewards: Is IRS Digging In or Changing Its Mind?

Crypto industry groups had hoped to use the tax refund case of Jarrett v. United States, No. 3:21-cv-00419 (M.D. Tenn.) as the vehicle to prove that staking rewards received by a crypto validator only trigger gain upon the...more

McDermott Will & Emery

Jarrett Leaves Unanswered Questions on Taxation of Staking Rewards

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In the latest turn of events for the closely followed Jarrett case concerning the taxation of staking rewards, on September 30, 2022, the US District Court for the Middle District of Tennessee granted the United States’...more

Fox Rothschild LLP

Beware of the Exempt Organization Examination: IRS Audits of Charities are Becoming More Common

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As the Internal Revenue Service ramps up its audit staff, its gaze is extending beyond the for-profit sector. IRS audits of public charities are also increasing. We have recently assisted several charities with their...more

Proskauer - Tax Talks

The Biden Administration Proposes Changes to the Taxation of Partnerships

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On March 28, 2022, the Biden Administration proposed certain limited changes to the taxation of partnerships. In short, the Administration’s proposals would (i) prevent related partners in a partnership that has made a...more

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