Podcast - Betty: Glamour en pasarela, caos contable y tributario
REFRESH Five Tax Traps for Business Lawyers Advising Nonprofit Organizations
How to Prepare for the IRS’s “New 90-Day Pre-Examination Compliance Pilot” Audit Process
Jones Day Presents: LB&I Examination Strategies: Responding to IDRs
Jones Day Presents: LB&I Examination Strategies: Process Overview
Jones Day Presents: Strategies for Dealing with the IRS: The IRS Examination
The Internal Revenue Service (“IRS”) audits 1% to 2% of small business income tax returns annually for one of two reasons: (1) something about the return (or information reported on the return) flagged the return for a closer...more
On January 23, 2026, the Brazilian Federal Revenue Service (“RFB”) published Interpretative Declaratory Act (“ADI”) No. 1/2026, which addresses the use of taxes paid abroad by directly or indirectly controlled or affiliated...more
There are over 150 types of penalties in the Internal Revenue Code (IRC). One frequent penalty that the Internal Revenue Service (IRS) asserts is the accuracy penalty under IRC Section 6662....more
A couple of years ago, I wrote a blog about the importance of sending any correspondence to the Internal Revenue Service via Registered or Certified Mail or by an approved overnight courier, rather than relying solely on the...more
The U.S. Internal Revenue Service (IRS) appears to be entering a new and far more aggressive phase of enforcement focused on taxpayers claiming Puerto Rico residency and Act 60 (formerly Act 22) incentives or benefits. The...more
It’s not at all unusual to encounter the owner of a New York business who dreams about leaving the State. The reasons often given for the desired move include, among others, the cost of doing business in New York, the State’s...more
Earlier this year, we unpacked the elements of tax fraud, how the Internal Revenue Service (IRS) approaches fraud in civil and criminal settings, and the penalties and consequences that can follow. That discussion focused on...more
California residents seeking to change their residency status and avoid California tax must be prepared to substantiate their relocation. Simply moving to another state is not enough to relinquish California residency and tax...more
How might marrying a non-US citizen affect your taxes? What are some of the hidden issues that the IRS, California, and other state tax agencies may raise in an audit?...more
In a recent decision, the New York Tax Appeals Tribunal issued a sharp reminder to ‘snowbirds’ that changing domicile is about substance, not paperwork. In Matter of John J. Hoff & Kathleen Ocorr-Hoff, DTA No. 850209 (N.Y....more
Is the burden of proof on the IRS during an Audit? It might shock you to learn that the burden of proof in an IRS audit, and in most dealings with the IRS, lies with the U.S. taxpayer, not the IRS....more
As year-end approaches, it is an opportune time for companies to run an internal audit of their nonqualified deferred compensation plans to flag any potential violations of IRC Section 409A (“Section 409A”)....more
Kilpatrick’s David Hughes recently spoke at the Institute for Professionals in Taxation (IPT) Sales Tax Symposium on “Proactive Sales Tax Strategies for Effective Risk Management and Compliance.” The session addressed...more
A decade ago, the IRS audited and brought cases against numerous taxpayers who claimed residency in the U.S. Virgin Islands to take advantage of a highly touted benefit whereby bona fide Virgin Islands residents could claim a...more
In its ongoing crusade against so-called “basis-shifting” transactions, the Internal Revenue Service has created widespread uncertainty regarding the tax treatment of routine transactions. For example, last year, the IRS...more
Why do you need an experienced tax attorney when tax issues strike? What do you need to know about communications with the IRS and California's tax agencies?...more
Are you searching for information on how to choose the right tax attorney? Are you a U.S. taxpayer who has a challenge with the IRS or a state tax agency? Are you facing an IRS or state tax audit? Are you an American...more
In today's complex and ever-evolving business landscape, tax due diligence has emerged as a critical component of financial analysis and risk management in mergers, acquisitions, and other significant business transactions....more
The Internal Revenue Service (“IRS”) released an update to its plan to transform agency work and improve taxpayer experience. The update to the Strategic Operating Plan provides “an outline of the major projects and outcomes...more
In his State of the Union address, President Joseph Biden targeted tax breaks for corporations and wealthy individuals who use private jets as part of a broader goal to make big corporations and the wealthy pay “their fair...more
On February 21, 2024, the IRS announced plans to begin audits on aircraft that may be used for both business and personal purposes. This push is a part of the IRS’s broader focus on improving tax compliance in high-income...more
Many taxpayers have art collections. However, the art collections of some high-net-worth individuals, family offices, and business taxpayers may draw the unwanted eye of the IRS. With the increased focus on auditing...more
The IRS has been understaffed for many years, and this has led to a decline in the number of audits conducted. The personnel shortage has also made it difficult to keep up with the growing complexity of the tax code and to...more
On September 8, 2023 the IRS announced a sweeping effort to focus enforcement efforts on high-income individuals, partnerships, and corporations. On September 20, 2023 the IRS announced that it will establish a special...more
For many business owners, tax season can be stressful. These four tips can help you lessen the chances of triggering a tax audit....more