Silver Moss Properties, LLC v. Commissioner: A Tax Court Showdown Over Conservation Easements and the Right to Jury Trial... [ read ]
Joel N. Crouch delves into the Tax Court's recent decision in Silver Moss Properties LLC v. Commissioner and the key areas of focus of the IRS's continued scrutiny.
Is the Issue of Fraudulent Conduct by the Return Preparer and the Tax Assessment Statute of Limitations Headed to the U.S. Supreme Court?... [ read ]
Joel N. Crouch analyzes whether the U.S. Supreme Court may soon weigh in on a critical tax controversy: does the indefinite statute of limitations for tax assessments apply when fraud is committed by a return preparer without the taxpayer's knowledge?
How an IRS PLR Can Help with a Missed IRA Rollover Due to Fraud... [ read ]
Matthew L. Roberts examines how an IRS Private Letter Ruling can provide critical relief for taxpayers who miss the IRA rollover deadline due to fraud.
A Step in the Right Direction: Appeals Case Memos can now be Shared with Taxpayers... [ read ]
Firm partner Jeffrey M. Glassman explores a major win for transparency in tax disputes: the IRS Independent Office of Appeals will now share Appeals Case Memoranda (ACMs) with taxpayers upon informal request.
OBBBA Revises Existing GILTI Tax Rules Applicable to CFCs... [ read ]
Matthew L. Roberts analyzes how the One Big Beautiful Bill Act (OBBBA) rewrites key provisions of the GILTI regime for US shareholders of controlled foreign corporations.
State Disasters Now Qualify for Federal Tax Relief... [ read ]
Nick S. Pegelow unpacks the important expansion of the IRS's disaster relief powers that could provide a lifeline to taxpayers impacted by state-declare emergencies.
IRS Focus Turns to Form 3520-A and Foreign Grantor Trusts... [ read ]
Firm partner Matthew L. Roberts examines the IRS's intensifying scrutiny of Form 3520-A and foreign grantor trusts and the increased audit risks that come along with these changes.
New ERC Laws are Here: What Are They?... [ read ]
Firm partner Jeffrey M. Glassman breaks down the sweeping new rules regulating the Employee Retention Credit and the new risks for employers and advisors alike.
Strategic Considerations for Tax-Exempt Status Revocation: Appeals and Litigation... [ read ]
Firm partner Jeffrey M. Glassman continues his deep dive into the IRS examination landscape and the critical next steps for organizations to resolve matters favorably.
5 Things You Should Know Now About IRS BBA Partnership Audits... [ read ]
Firm partner Matthew L. Roberts breaks down the complex world of IRS partnership audits under the Bipartisan Budget Act of 2015 (BBA) and the critical areas every professional should understand.
