Resources Archive
July 5, 2023
IRS Criminal Investigation of Malta Pension Plan...
[ read ]
Last week the IRS' interest in the Malta Pension Plan (MPP) took a very serious turn as IRS Criminal Investigators started contacting professionals and taxpayers who participated in MPPs. The first indication of IRS interest in MPPs was when MPPs were included on the 2021 IRS Dirty Dozen list.
June 28, 2023
Michael A. Villa, Jr. appointed Chair of the American Bar Association Tax Section Civil & Criminal Penalties Committee... [ read ]
June 27, 2023
IRS Badges of Fraud...
[ read ]
On June 22nd, the U.S. Tax Court released a memorandum decision in Kamal v. Commissioner, T.C. Memo 2023-80, which is a helpful reminder of what evidence a court will consider when the IRS has proposed a 75% civil fraud penalty. In addition, Kamal is another example of the potential risks of filing a Tax Court petition.
June 21, 2023
How Long Does the IRS Have to Challenge an ERC Refund?...
[ read ]
For employers who have either filed for or have received payment for Employee Retention Credit (ERC) claims, the significant surge in IRS examinations of ERC claims is similar to the shark in the movie Jaws. You know he is out there, but you don't know where he will bite and when.
June 21, 2023
Jeffrey M. Glassman named Co-Chair of the 2023-2024 State Bar of Texas (SBOT) Tax Section's Tax Controversy Committee... [ read ]
June 15, 2023
The Employee Retention Credit: Some Guidance Exists But Uncertainty Remains...
[ read ]
If you follow the Meadows Collier blog, you are likely already aware that the IRS is focused on improper Employee Retention Credit ("ERC") transactions. My colleagues' previous blog posts described how the IRS has added Employee Retention Credit transactions to its annual "Dirty Dozen" list. We are now seeing the IRS begin new examinations related to the ERC and, in other cases, pursue criminal indictments. My colleagues have also described how the IRS is focusing on tax preparers and promoters involved in improper claims of the ERC. In sum, the IRS is serious about improper ERC claims.
June 9, 2023
California Introduces Settlement Proposal for Micro-Captive Insurance Transactions and Syndicated Conservation Easement Transactions. What's the IRS' Plan?...
[ read ]
On May 31, 2023, the California Franchise Tax Board (FTB) issued Notice 2023-02 providing a limited time settlement opportunity to taxpayers who participated in potentially abusive Micro-Captive Insurance (MCI) and Syndicated Conservation Easement (SCE) transactions.
June 8, 2023
15th Annual NYU Tax Controversy Forum... [ read ]
June 6, 2023
Damon Rowe - Tax Alliance Conference Bootcamp... [ read ]
June 6, 2023
Meadows Collier June Webinar... [ read ]
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