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Allen Barron, Inc.

Is the Burden of Proof on the IRS During an Audit?

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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

Hone Maxwell

I haven’t filed my taxes or international reports, now what? It might be the best time to ask

Hone Maxwell on

Did you just find out that as a dual citizen you have to report U.S. taxes even if you live abroad? Did you just discover you needed an FBAR, Form 5471, GILTI calculation, Form 3520, Form 5472, or other foreign reporting?...more

Allen Barron, Inc.

What You Need to Know About the IRS Math and Taxpayer Help Act

Allen Barron, Inc. on

What do you need to know about the IRS Math and Taxpayer Help Act? What is the status of the reforms contained within the provisions of H.R. 998?...more

Troutman Pepper Locke

Key Advantages of Using REITs by Funds for Foreign Investors — The Tax Blueprint: Structuring Funds, Joint Ventures, and REITs

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Welcome back to "The Tax Blueprint: Structuring Funds, Joint Ventures, and REITs." In the third episode of our three-part series, hosts Saba Ashraf, Aresh Homayoun, and Tom Phelan explore the advantages that may be offered to...more

Blake, Cassels & Graydon LLP

L’Agence du revenu du Canada modifie en profondeur le Programme des divulgations volontaires : faits saillants

Dans un souci de rendre le Programme des divulgations volontaires (le « PDV ») plus attrayant, l’Agence du revenu du Canada (l’« ARC ») y a apporté d’importants changements, lesquels entrent en vigueur le 1er octobre 2025....more

Rivkin Radler LLP

Visiting the Sins of the Tax Preparer Upon the Taxpayer? The Fraud Exception to the Limitations Period on Assessment

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As we discussed a few weeks ago, the IRS is charged with enforcing the U.S. federal tax laws; i.e., it is responsible for processing tax returns and for collecting taxes. As part of its collection function, the agency may...more

Allen Barron, Inc.

Managing an IRS Correspondence Audit

Allen Barron, Inc. on

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

Barnea Jaffa Lande & Co.

New Voluntary Disclosure Procedure – Effective Until August 31, 2026

On August 25, 2025, the Israel Tax Authority (ITA) published a new directive entitled “Voluntary Disclosure Procedure – Temporary Order.” The aim of this procedure is to encourage both Israeli and foreign residents who have...more

Allen Barron, Inc.

IRS and State Tax Complications of Offshore Investments

Allen Barron, Inc. on

What do you need to know about the IRS and state tax complications of offshore investments? It is common to have international investments in your portfolio, not to mention business interests. How do you navigate the...more

Vinson & Elkins LLP

Civil Tax Fraud: Should 75 Percent Appear Too Small, Be Thankful the IRS Doesn’t Take It All

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Mistakes happen, including when it comes to reporting and paying taxes. And for taxpayers and their advisors, those mistakes can lead to costly consequences, as the Internal Revenue Code (“Code”) allows the Internal Revenue...more

Kilpatrick

The Illinois Franchise Tax: A Four-Part Series

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This four-part series of articles is intended to provide a deep dive into the Illinois State Franchise Tax (the “Franchise Tax”) and should be read sequentially to be best understood....more

Rivkin Radler LLP

Drop & Swap Like-Kind Exchange Passes Muster in New York

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New York’s personal income tax law, like that of other states, conforms with the federal system of income taxation. The reason typically given for such conformity is to simplify tax return preparation, improve compliance and...more

Whiteford

Client Alert: The Employee Retention Credit and How to Handle Unprocessed Claims

Whiteford on

The Employee Retention Credit (ERC) was introduced as part of the March 2020 Coronavirus Aid, Relief, and Economic Security (CARES) Act to encourage businesses to maintain their workforce during the economic disruptions of...more

ASKramer Law

Tax-Loss Harvesting Part I: Overview

ASKramer Law on

What is tax-loss harvesting? “Tax-loss harvesting,” in its simplest form, is the sale of a capital asset at a loss to “mop up” tax that would otherwise be due on capital gain from the sale of another capital asset. Capital...more

Allen Barron, Inc.

The Risk of California FTB Audits is Increasing

Allen Barron, Inc. on

Did you know that the number of California FTB audits is increasing when compared to the trend of IRS audits in 2025? The California Franchise Tax Board, or FTB, has recently invested in advanced data processing systems and...more

Freeman Law

Tax Cout in Brief | Christiansen v. Commissioner

Freeman Law on

The Tax Court in Brief - Freeman Law’s “The Tax Court in Brief” covers substantive Tax Court opinion, providing a brief of its decisions in clear, concise prose....more

McDermott Will & Schulte

What to know about Illinois’s 2025 amnesty programs

On May 31, 2025, the Illinois General Assembly passed House Bill 2755, which contains three amnesty programs the state estimates will substantially increase its coffers. Illinois Governor JB Pritzker signed the bill into law...more

Frost Brown Todd

Substantiating the Right to Claim QSBS Tax Benefits | Part 1

Frost Brown Todd on

Section 1202 provides an exclusion from capital gains when a stockholder sells qualified small business stock (QSBS), assuming all eligibility requirements are satisfied. Section 1045 provides for the tax-free rollover of...more

White & Case LLP

The IRS Revamps the Pre-Filing Agreement Program for LB&I Taxpayers

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On June 17, 2025, the Internal Revenue Service ("IRS") announced improvements to its Pre-Filing Agreement ("PFA") program. The IRS press release is available here. The PFA program allows Large Business & International...more

IR Global

Why filing early makes sense

IR Global on

Filing your 2024-25 Self-Assessment return early means faster refunds, better budgeting, and no deadline stress. Do not delay, start gathering your tax details today....more

DLA Piper

Belgian VAT Authorities Publish New Circular Letter Regarding Late Input VAT Recovery

DLA Piper on

Seven years after relevant judgments from the CJEU, the Belgian VAT authorities now (broadly) allow the recovery of input VAT beyond the standard Belgian limitation period of three years, subject however to strict conditions....more

Allen Barron, Inc.

You Need an Experienced Tax Attorney when Tax Issues Strike

Allen Barron, Inc. on

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

McDermott Will & Schulte

Potential Refund Opportunity for Interest and Penalty Amounts Accrued During COVID-19 Federally Declared Disaster

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

Freeman Law

Posts, Profits, & Penalties | Tax Law & Social Media | Part 4

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As discussed in Part 2, there are many ways social media creators earn income. Social media income, like all income, needs to be reported on federal tax returns....more

Amundsen Davis LLC

Does My Company Qualify for Wisconsin’s Voluntary Disclosure Program?

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Taxes and their applicable laws can be confusing for even the most savvy businesspeople. For any number of reasons, businesses and individuals fall out of compliance with tax reporting requirements and become exposed to...more

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