Resources

In recent months, the IRS has revised a public announcement and issued an LB&I Practice Unit concerning information returns and penalties associated with foreign trusts. The public announcement attempts to educate...

In In January 2024, I wrote a series of blog posts about some changes to the Employee Retention Credit (“ERC”) laws that were being introduced in Congress: Many of those changes are now law. On July 4, 2025, President...

I previously wrote about IRS tax-exempt organization examinations, where tax-exempt status is on the line. Now, in this post, I will focus on what happens if you cannot resolve the matter favorably with the IRS examination...

Partnerships are an enigma under federal tax law. Although the partnership files an annual income tax return (i.e., Form 1065), the partners report their allocable share of the partnership’s tax items on their income tax...

Cooler minds prevailed: The Taxpayer Advocate convinced the IRS to ‘undo’ a recent, highly criticized change to the Voluntary Disclosure Program that required the taxpayer’s admission of willfulness prior to...