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Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for December 15, 2025 – December 22, 2025....more
Should courts respect a transaction for tax purposes, when it otherwise complies with the technical requirements of the Internal Revenue Code and regulations? When should a court take the next step and consider the economic...more
New Hampshire passed legislation this year to establish a one-time opportunity for taxpayers to pay all outstanding taxes and receive amnesty from penalties and one-half of the interest that has accrued since the tax was due....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
The Los Angeles Dodgers leveraged deferred compensation contracts to gain $241.44 million in player value for 2026 while paying half that amount. With two World Series in the last four years and another bid this year, this...more
To make its voluntary disclosure program (VDP) more attractive, the Canada Revenue Agency (CRA) has implemented significant changes to the program effective October 1, 2025. At a high level, the new VDP...more
One of the new realities for U.S. taxpayers includes the responsibility for managing an IRS correspondence audit. What should you do if you are contacted regarding any form of IRS audit? Did you know the present majority of...more
Le ministère des Finances a publié récemment des projets de propositions législatives visant à mettre en œuvre des mesures élargissant les pouvoirs de vérification de l’Agence du revenu du Canada (l’« ARC »)....more
Taxpayers who made payments to the Internal Revenue Service (IRS) that included underpayment interest and/or failure-to-file/pay penalties that accrued during all or part of the period between January 20, 2020, through July...more
Could your motion picture agreement, recording agreement, or sports contract be a non-qualified deferred compensation arrangement? You may think it unlikely, but a non-qualified deferred compensation arrangement refers to any...more
On Friday, April 11, 2025, the Internal Revenue Service issued Notice 2025-24 (the “Notice”), which waives applicable penalties under the Internal Revenue Code to participants in, and material advisors to, reportable...more
In its recent decision in United States v. Leeds, the United States District Court for the District of Idaho upheld the application of willful penalties against a deceased husband for failing to report certain foreign bank...more
Every parent remembers when their child learns the meaning of the word “no.” That moment often comes as a shock because, up until that moment, most children are models of obedience and unconditional trust. When children learn...more
On 10/24/24, the National Taxpayer Advocate shared on its NTA Blog that the IRS has discontinued its policy of automatically imposing penalties for late submissions of Form 3520, which pertains to foreign gifts and...more
There are two recent taxpayer-friendly updates of note in the international tax filing arena. First, Internal Revenue Service (“IRS”) Commissioner Danny Werfel recently announced that the IRS is ending its automatic...more
What is willful blindness according to the IRS? How is this important in tax cases involving unreported or under-reported income, disclosure of offshore assets and income, FinCEN Form 114 (more commonly referred to as an...more
On 9/19/24, the IRS issued a warning to taxpayers regarding OIC (Offer in Compromise) Mills that are taking advantage of taxpayers. OIC Mills promoters claim that their services are necessary to resolve taxpayer unpaid taxes...more
Recent changes implemented by Secure Act 2.0 provide a powerful retirement opportunity. Starting in 2024, Congress changed the way that 529 accounts work....more
Even global icons like Beyoncé, among the wealthiest entertainers on the planet, are not immune to IRS scrutiny. Recently, Queen Bey found herself entangled in a dispute with the Internal Revenue Service (IRS) over an alleged...more
The Massachusetts Department of Revenue (DOR) recently announced a tax amnesty program for non-filers and those with outstanding tax liabilities. From November 1 to December 30, 2024, most penalties for eligible taxpayers who...more
What is the statute of limitations for an IRS audit? What rules extend the window for an IRS audit? How long does the IRS usually have to complete an audit of your taxes? Everyone may have a little fear in the back of...more
The Commonwealth of Massachusetts will offer a limited tax amnesty for certain “eligible taxpayers” from Nov. 1 through Dec. 30. “Eligible taxpayers” can forward and bring their tax liabilities up to date and receive a...more
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
On July 24, 2024, Normative Instruction No. 2,205/ of the Brazilian Federal Revenue Service (the "Instruction”) was published, that regulates Article 25, paragraph 9-A, and Article 25-A of Decree No. 70,235/1972, establishing...more
El IRS emitió el Consejo Fiscal 2024-37, el 24 de abril de 2024, para informar a los contribuyentes que no pueden pagar su deuda tributaria completa o si pagar les causaría dificultades financieras, que deberían considerar...more