Changes to IRS Voluntary Disclosure Program are Coming... [ read ]
Jeffrey M. Glassman shares insights from the American Bar Association's 2025 Criminal Tax Fraud and Tax Controversy Conference, where IRS Criminal Investigation Chief Guy Ficco announced that changes to the IRS voluntary disclosure program are coming.
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Jeffrey M. Glassman
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Does Santa Have Tax Problems? A Look at Kris Kringle's Potential IRS Nightmares... [ read ]
Joel N. Crouch takes a lighthearted look at what would happen if Santa Claus became a US taxpayer. From employment taxes for elves to millions of gift tax returns, it's a festive reminder that even the North Pole isn't safe from tax compliance.
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Joel N. Crouch
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Can the IRS Search My Emails? The Lesson from Mukhi... [ read ]
Matthew L. Roberts explores a question with big implications for taxpayers in litigation: can the IRS obtain your personal emails?
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Matthew L. Roberts
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NCAA Transparency Advocate Accuses UCLA of Skirting IRS Rules on Tax Exemptions, NIL Payments... [ read ]
Joseph A. Rillotta examines allegations that UCLA used a tax-exempt charity to route NIL payments to football players, potentially circumventing rules on charitable deductions and giving the program an edge with NIL.
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Joseph A. Rillotta
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Recent Tax Case Shows Importance of Proof of Mailing with IRS... [ read ]
Joel Crouch highlights a recent federal court decision that reinforces a critical best practice when dealing with the IRS: always keep proof of mailing.
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Joel N. Crouch
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IRS Foreign Information Returns: A Common Nightmare for New U.S. Residents... [ read ]
Matthew L. Roberts breaks down the complex foreign information return requirements that often catch new U.S. residents by surprise.
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Matthew L. Roberts
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IRS Foreign Information Returns: A Common Nightmare for New U.S. Residents... [ read ]
Matthew L. Roberts breaks down the complex foreign information return requirements that often catch new U.S. residents by surprise.
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Matthew L. Roberts
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Why Metadata Matters When Working with the IRS... [ read ]
Joel N. Crouch breaks down why metadata has become a critical factor in IRS examinations and tax litigation. Using the recent Lamstall Holdings Tax Court case as a backdrop, Mr. Crouch explains how metadata can influence penalty assertions, authenticate documents, and shape the evidentiary record.
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Joel N. Crouch
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Another Texas Contractor's Sales and Use Tax Conundrum: Is it "Maintenance" or Just Maintenance?... [ read ]
In the world of Texas sales and use tax, many concepts have proven to be challenging for contractors. Once such concept is the notion of "maintenance" given that it is generally excluded from work that may otherwise qualify as taxable repair and/or remodeling work. David Colmenero and Alex Pilawski discuss this concept of nontaxable "maintenance" and some of the issues it presents.
PFIC Rules & Late Form 8621: Understanding Your IRS Compliance Options... [ read ]
Matthew L. Roberts discusses the complexities of the PFIC tax rules and what happens when a taxpayer misses a Form 8621 filing or fails to make a timely PFIC election.
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Matthew L. Roberts
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