Under federal tax law, certain entities must file IRS Form 5472 to report specified transactions with related parties. To ensure compliance with this information return reporting obligation, Congress allows the IRS to impose...
Category: Blog
The IRS Acts on the ERC Two-Year Deadline – Is It Enough?
April 28, 2026
Last month, I wrote an article encouraging employers to secure tax litigation counsel sooner rather than later if they might need to file a lawsuit to obtain Employee Retention Credits (“ERCs”). That article can...
A recent decision from the 15th Court of Appeals in Texas could provide a windfall for entities engaged in providing airline transportation services. In a case involving American Airlines, Inc. (“American...
The Texas Supreme Court Addresses What “In This State” Means in Sourcing the Sale of TPP For Texas Franchise Tax Apportionment
April 13, 2026
In a case involving the sale of bunker fuel, the Texas Supreme Court recently addressed the meaning of a sourcing statute for Texas franchise tax. [1] The taxpayer argued that revenues from the sale of its bunker fuel...
Federal tax law has long required taxpayers to report their receipt of foreign gifts and inheritances and certain transactions with foreign trusts on IRS Form 3520. Although the IRS aggressively enforces this...