Is non-compliance a problem money can solve? The IRS seems to think so, rolling out last week yet another set of enforcement initiatives based on Inflation Reduction Act funding. Like other recent initiatives that target...
Improper Art Donation Deduction Promotions: IRS Sounds Alarm
The IRS is warning taxpayers not to claim improper art donation deductions (HERE) and provides tips to help people avoid getting ensnared by an illicit art donation promotion. The IRS says the following about how the scheme...
Saved by the Bell: Treasury Extends Deadline for Reporting Owners of Newly Formed Entities
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...
Distinctions that Make a Difference: Federal Circuit Holds that Various Substance Over Form Doctrines are Not Interchangeable
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....
More Money, More Problems: IRS Further Targets “Wealthy” Taxpayers with New Special Team
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. Yesterday, the...