The IRS recently issued a news release identifying seven signs that a business’s Employee Retention Tax Credit (the ERC) may be incorrect. The IRS identified these warning signs based on feedback from tax professionals and...more
El 8/25/23, el IRS anunció que el aumento de las tasas de interés para el cuarto trimestre del 2023 aumentaría al 8% anual para el trimestre calendario que comienza el 10/1/23 para los impuestos adeudados pero no pagados en...more
On 8/25/23, the IRS announced that Interest rates increase for the fourth quarter 2023 would increase to 8% per year for the calendar quarter beginning 10/1/23 for taxes owed but not fully paid by individual taxpayers...more
The U.S. Department of the Treasury and the Internal Revenue Service (IRS) have finalized rules for the recapture of erroneously claimed Employee Retention Credits (ERC) and other tax credits provided to employers for...more
Summary: In this non-precedential opinion (see section 7463(b)), the Tax Court addresses whether or not to uphold an accuracy-related penalty assessed to taxpayer, Ashenafi Getachew Mulu (Mulu). Mulu hired David...more
Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of August 29, 2022 – September 2, 2022....more
Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of March 13, 2022 – March 19, 2022. Additionally, for continuing updates on the tax impact of...more
Accuracy-related penalties under section 6662 are among the most common penalties in the Tax Code. As a result, they are often at issue in tax litigation against the IRS. That raises the question: What are the burdens of...more
A change in presidential administrations brings with it the uncertainty of what the political, legal and tax landscape will look like in the future. Statements from the Commissioner of the Internal Revenue Service and the...more
It is tax season once again. While the Internal Revenue Service (IRS) has extended this year’s filing deadline to May 17, 2021 for individuals, businesses must still file by April 15, and all U.S. taxpayers must ensure that...more
Freeman Law’s “The Tax Court in Brief” covers every substantive Tax Court opinion, providing a weekly brief of its decisions in clear, concise prose. The Week of October 31 – November 6, 2020 - Glade Creek Partners,...more
There are Taxpayers that understate income, overstate expenses and present fraudulent claims on their tax returns for credits and deductions. These Taxpayers run the risk of being identified by the IRS and having IRS...more
Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of February 25 – March 1, 2019. February 25, 2019: The IRS issued Revenue Ruling 2019-05,...more
The National Taxpayer Advocate 2017 Report to Congress states that the Accuracy-Related Penalty under Internal Revenue Code Section 6662 remains the number one most litigated tax issue and has been over the last four years. ...more
The IRS Automated Underreporter Matching Process matches Tax Returns against Information Returns. IRS states that there were approximately 150 million individual tax returns filed in 2017 and about 25 million of them (17%)...more
On November 2, 2015, President Obama signed into law the Bipartisan Budget Act of 2015, which included a new federal audit regime for partnerships and entities classified as partnerships for federal income tax purposes (the...more
According to the IRS, accuracy related penalties remain the number one most litigated tax issue. The Internal Revenue Code authorizes the IRS to impose penalties if a Taxpayer is negligent or disregards tax rules and...more
The Bracewell Tax Report is a periodic publication focused on developments in federal income tax law, including the recently enacted Tax Cuts and Jobs Act (TCJA), with emphasis on how such developments impact the energy,...more
Certain important changes took effect on January 1, 2018 regarding underpayment of taxes by partnerships as well as the handling of tax inquiries including audits. The biggest change is that the IRS can now come to collect...more
As you’ve surely heard by now, the Bipartisan Budget Agreement of 2015 (“BBA”) enacted new IRS procedures for partnership audits for tax years beginning on or after January 1, 2018. The new audit rules allow the IRS to...more
In an effort to comply with the increasing complexity of the Internal Revenue Code (the “Code”) and the regulations promulgated thereunder, many taxpayers are looking to tax preparation software for assistance in preparing...more
Legislation enacted in November 2015 will fundamentally change the way the Internal Revenue Service (IRS) examines entities treated as partnerships for U.S. federal tax purposes, including how it assesses and collects tax...more
On December 3, 2013, the U.S. Supreme Court unanimously reversed the U.S. Court of Appeals for the Fifth Circuit and held that (1) a federal district court in a partnership-level proceeding had jurisdiction to determine the...more