Meadows Collier welcomes two longtime and accomplished business litigators, Craig F. Simon, Partner and Paula E. Reichenstein, Senior Counsel. These two attorneys bring more than 55 years of litigation experience to...
IRS Successfully Stifles Taxpayer’s Effort for Judicial Review of IRS Cryptocurrency Guidance
The IRS is a bit thin-skinned when it comes to the income taxation of cryptocurrency transactions. While it zealously advocates the legal soundness and correctness of its views, the IRS is just not ready for criticism –...
Go, Hedgie, Go: Hedge Fund challenges IRS’ Position on Limited Partner Exception to Self-Employment (SE) Tax
The tax community has been searching for a mighty torch bearer to challenge the IRS’ position that a limited partner cannot wear two hats: one, as a service provider that receives guaranteed payments subject to...
IRS Announces New Audit Campaign Focusing on Partnership Distributions
Do you have 10, 20 or even 30 years of data to prove up basis in a partnership interest? Well, I hope so, because the IRS will be asking for it as part of a new IRS Compliance Campaign. Just last month, on its website the IRS...
Treasury Marches Forward with Efforts to Create a National Database of Business Entities
You know the news is BIG when the Government spends 308 pages explaining (justifying) rules where the rules themselves take up only 22 pages. Today the Treasury Department announced final regulations requiring business...