On December 2, 2016, the IRS issued final regulations outlining increased installment agreement entrance fees while adding a reduced fee for online payment agreements (click here to view the Federal Register which...
As the old adage goes, no good deed goes unpunished. In McClendon vs. United States, decided on November 17, 2016, the federal district court for the Southern District of Texas upheld the IRS’ trust fund penalty...
Last month, I blogged on the IRS’ identification of Code Section 831(b) micro captives as “transactions of interest,” which triggered an obligation by taxpayers and material advisors to formally disclose the details of...
In October of 2016, the IRS issued final regulations under IRC code section 385. The final regulations cover a number of issues under Internal Revenue Code (“IRC”) section 385. IRC section 385 deals, in general, with...
On December 23rd the IRS issued Notice 2017-10 (here), which adds syndicated conservation easements to the category of transactions that require formal disclosure by investors and advisors to the IRS. Any taxpayer or...
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