The Texas Supreme Court Addresses What "In This State" Means in Sourcing the Sale of TPP For Texas Franchise Tax Apportionment... [ read ]

David Colmenero and Alex Pilawski examine the Texas Supreme Court's recent decision addressing the statutory meaning of "in this state" for purposes of sourcing revenue from the sale of tangible personal property in arriving at the Texas franchise tax apportionment factor.

IRS Form 3520 Penalties: What They Are and How to Qualify for Relief... [ read ]

Matthew L. Roberts examines the IRS's enforcement of Form 3520 and the significant penalties that may arise from late or missed filings.

Texas Court Vacates FinCEN Beneficial Ownership Reporting Rule for Non-Financed Real Estate Transactions... [ read ]

Joseph Rillotta examines recent developments concerning the Treasury Department's efforts to collect beneficial ownership information, including the U.S. District Court for the Eastern District of Texas vacating FinCEN's 2024 rule on non-financed residential real estate transactions.

Meadows Collier Partners Submit Comments on Proposed Updates to the IRS's Voluntary Disclosure Practice... [ read ]

ERC Litigation: The Time to Line Up Litigation Counsel is Now... [ read ]

Jeffrey M. Glassman discusses the approaching litigation deadlines facing taxpayers with denied Employee Retention Credit (ERC) refund claims.

IRS Notches Another Victory in Safdieh on IRS Form 5471 Penalty... [ read ]

Matthew L. Roberts examines the evolving judicial landscape surrounding IRS Form 5471 penalties in light of the Second Circuit's recent decision in Safdieh v. Comm'r.

The Fifteenth Court of Appeals Holds that Returnable Containers May Qualify for the Manufacturing Exemption Creating Potential Opportunities for Refund Claims... [ read ]

David E. Colmenero and Alex J. Pilawski examine the Fifteenth Court of Appeals' recent decision in Hancock v. ChampionX, LLC, which holds that returnable containers may qualify for Texas's Manufacturing Exemption.

Navigating the Federal Tax Consequences on Settlements and Judgments... [ read ]

Matthew L. Roberts explores the federal income tax consequences associated with litigation settlements and judgments, focusing on how the origin of the claim doctrine determines whether settlement payments are taxable or non-taxable.

FBAR Willfulness Easier to Prove Under Recent Reyes Second Circuit Decision... [ read ]

Matthew L. Roberts examines the Second Circuit's recent decision in U.S. v. Reyes and its significance to IRS compliance options.

Fifth Circuit Rejects IRS "Passive Investor" Test for Limited Partners in Self-Employment Tax Case... [ read ]

Naveid P. Jahansouz examines the Fifth Circuit's rejection of the IRS's effort to restrict the limited partner exception to passive investors.