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Saved by the Bell: Treasury Extends Deadline for Reporting Owners of Newly Formed Entities
By on September 27, 2023
Uncle Sam's curiosity is often insatiable. But at least he is willing to wait an additional 90 days, based on a newly proposed rule by the Treasury Department. Of course I'm talking about the new disclosure rules mandated by the 2021 Corporate Transparency Act, which require many private businesses, and virtually all small businesses, to disclose to the U.S. government the identities of their owners and other basic information about them.
By on September 22, 2023
There are various interactions of the substance over form doctrine, such as step-transaction, economic substance, sham, among others. As the Federal Circuit reminded us all yesterday, the iterations are not interchangeable. I'm referring to the Federal Circuit's September 21, 2023 decision in GSS Holdings (Liberty) Inc. v. the U.S.
The Squeaky Wheel Gets the Grease? Employers Should Consider Filing Lawsuits to Obtain ERC Refunds
By on September 21, 2023
Just last week, the IRS announced that it was no longer processing any new Employee Retention Credit (ERC) claims amid a surge in questionable claims. While there may be questionable claims being filed, there are plenty of legitimate claims that should be processed and refunded to employers.
More Money, More Problems: IRS Further Targets "Wealthy" Taxpayers with New Special Team
By on September 21, 2023
After announcing the hiring of new agents to audit the "wealthy," the IRS marches further down the war path by establishing a special pass-through organization to help with high-income compliance efforts.
Adding Bite to its Bark: IRS Announces Hiring of 3,700 to Audit Wealthy Taxpayers
By on September 18, 2023
IRS enforcement rhetoric is never a hollow threat. But given the IRS' limited resources historically, the saying "a barking dog seldom bites" sometimes held true. That is no longer the case, with the IRS announcing the opening of more than 3,700 positions to support its latest initiative to expand tax enforcement against high-income earners, partnerships, large corporations and promoters.
IRS Halts Processing of ERC Claims
By on September 14, 2023
On September 14, the IRS announced that it was immediately stopping processing of any new Employee Retention Credit (ERC) claims amid a surge in questionable claims. The moratorium on processing is effective immediately and will run through at least the end of the year.
By on September 8, 2023
On September 8th, the IRS, following a "top-to-bottom" review of enforcement efforts, announced that it will be shifting more enforcement efforts to "high-income earners, partnerships, large corporations and promoters abusing the nations' tax laws".