Williams Mullen's COVID-19 Comeback Plan: Tips for Virginia Real Estate Assessment Appeals in a COVID-19 Environment
The IRS recently concluded that certain commercial property assessed clean energy (“CPACE”) assets are “obligations . . . secured by an interest in real property” under Code Section 860G(a)(3) in a private letter ruling...more
The U.S. Court of Appeals for the District of Columbia Circuit (D.C. Circuit) on May 3, 2024, reversed the U.S. Tax Court (USTC) in Alon Farhy v. Commissioner, No. 23-1179 (D.C. Cir. May 3, 2024) by holding that...more
The U.S. Supreme Court rules that the IRS does not need to provide notice to innocent bank account holders when the summonses are issued in aid of collection of a delinquent taxpayer’s tax assessment. ...more
When is Written Managerial Approval Required? In 1998, Congress sought to provide additional protections to taxpayers through passage of the Internal Revenue Service Restructuring and Reform Act (the “Act”). Buried within...more
In a prior post, I discussed the dangers of playing Battleship with the IRS. Recently, taxpayers made a move and scored a hit with the Tax Court’s recently issued decision in Alon Farhy v. Commissioner, 160 T.C. No. 6 (April...more
In the federal income tax world, there are effectively two functions within the Internal Revenue Service (“IRS”). First, the IRS examines tax years and tax returns to determine whether the taxpayer has reported the correct...more
Third-party summonses. Taxpayers, individuals, and companies, alike, should be aware of the Internal Revenue Service’s (“IRS”) power to issue third-party summonses. Even more, interested parties should note that only parties...more
The Internal Revenue Service (IRS) must follow the “statute of limitations” as stated in Internal Revenue Code (IRC) Section 6501 to “assess” additional federal tax. Likewise, taxpayers must seek a tax overpayment or refund...more
To levy on Social Security benefits, the IRS generally issues Form 668-W to the Social Security Administration (“SSA”). After receipt of the Form 668-W, Notice of Levy on Wages, Salary, and Other Income, SSA will withhold...more
What is the Statute of Limitations? - The Internal Revenue Code limits the time in which the government may assess tax. There are two civil statutes of limitations. The first is the period during which the IRS can assess...more
An assessment results when the liability of a taxpayer is recorded in the office of the Secretary of the Treasury. The assessment establishes the right of the IRS to collect the tax. ...more
Despite the market disruption caused by the COVID-19 pandemic, sovereign wealth funds continued to make significant capital commitments to private funds during 2020, on a global basis. As the world emerges from the pandemic,...more
Many employers began to receive notices from the IRS in 2018 proposing the assessment of a payment against the employer for the tax years 2015 and 2016 under Section 4980H of the Internal Revenue Code. The issuance of these...more
Many individual taxpayers are rushing to prepay their real property taxes in anticipation of the new lower cap of $10,000.00. Not everyone will be able to take advantage of the tax planning idea. ...more
Campus Real Estate, Property Management, Tax Credits The 15th Annual Higher Education Real Estate Lawyers conference was held in San Francisco, where attendees listened to and learned from both in-house and outside counsel at...more
On November 2, 2015, President Barack Obama signed into law the Bipartisan Budget Act of 2015 (the Act). The Act overhauls the partnership audit and litigation rules in the Internal Revenue Code, repealing both the provisions...more
Thorny Exemption Issue Discussed - Limited Liability Company X owns property in the Town of Windham which it leases to Corporation Y. Both entities are tax exempt under the Internal Revenue Code. Both entities...more