The IRS is About to Go Public with Many Criminal Crypto Cases... [ read ]
According to a Bloomberg news update, the head of the IRS's Criminal Investigation division, Jim Lee, announced yesterday that the IRS is building "hundreds" of criminal digital asset cases. The IRS is about to make many of them public.
Go, Hedgie, Go: Hedge Fund challenges IRS' Position on Limited Partner Exception to Self-Employment (SE) Tax... [ read ]
The tax community has been searching for a mighty torch bearer to challenge the IRS' position that a limited partner cannot wear two hats: one, as a service provider that receives guaranteed payments subject to self-employment (SE) tax, and another, as an investor that receives his or her share of partnership income exempt from SE tax. And it appears we now have one.
Stacking ‘Em Deep: IRS Struggles to Respond to FOIA Requests... [ read ]
Still waiting on the IRS to respond to your FOIA request? Well, according to a recent Government update, you may be waiting a while longer.
New Tax Court Decision Brings Much-Needed Accountability to IRS Settlement Programs... [ read ]
When it comes to settlement programs, the IRS is reminiscent of the South Park character Cartman, who demands that everyone "Respect my Authoritah!" Historically taxpayers participating in IRS settlement programs were at the whim of the IRS' authority, which at times was exercised arbitrarily with no recourse to the taxpayer. Well, not anymore. I'm talking about the Tax Court's decision in Treece Financial Services Group v. Commissioner, 158 T.C. No. 6 (2022).
New Tax Court Case Reveals the IRS' Two-Front War Against Microcaptives... [ read ]
A recently filed Tax Court case has revealed just how much disdain the IRS has for microcaptives. And it is a lot. The case is SCC Holding Company of Pinellas, Inc. v. Commissioner, Docket No. 16285-22, filed in July 2022. At the time of filing, the taxpayer and the IRS were already long-time "friends." Starting in 2016, the IRS had issued a series of Notice of Deficiency covering tax years 2010 through 2016. Therein, the IRS disallowed deductions for captive insurance premiums and asserted a 40% penalty based on the IRS' determination that the microcaptive planning lacked economic substance and was not properly disclosed.
IRS Confirms 2023 Indexed Amounts... [ read ]
Our wealth transfer tax system provides taxpayers with exclusions from certain taxes. These exemptions are adjusted annually; the amount of the adjustment is tied to the Consumer Price Index. The IRS has published the 2023 indexed amounts.
The IRS Makes it Easier and Cheaper to Fix Foot Faults on S-Corp Elections... [ read ]
On October 7th, the IRS released Revenue Procedure 2022-19 which provides simplified measures for correcting six procedural missteps that the IRS says are resolvable without requesting a letter ruling. The IRS believes the relief provided in Rev. Proc. 2022-19 will reduce burdens on taxpayers and the government, facilitate increased taxpayer compliance with the rules for electing S corporation status, and reduce costs and delays in completing transactions involving S corporations and qualified subchapter S subsidiaries.
IRS Successfully Stifles Taxpayer's Effort for Judicial Review of IRS Cryptocurrency Guidance... [ read ]
The IRS is a bit thin-skinned when it comes to the income taxation of cryptocurrency transactions. While it zealously advocates the legal soundness and correctness of its views, the IRS is just not ready for criticism – especially the judicial kind.
IRS Announces New Audit Campaign Focusing on Partnership Distributions... [ read ]
Do you have 10, 20 or even 30 years of data to prove up basis in a partnership interest? Well, I hope so, because the IRS will be asking for it as part of a new IRS Compliance Campaign.
Treasury Marches Forward with Efforts to Create a National Database of Business Entities... [ read ]
You know the news is BIG when the Government spends 308 pages explaining (justifying) rules where the rules themselves take up only 22 pages. Today the Treasury Department announced final regulations requiring business entities to report details on their beneficial ownership to the federal government. No, today is not April 1 and my fingers are not crossed.
