The passive foreign investment company (PFIC) rules are complex and nuanced. Generally, a U.S. shareholder with a PFIC interest must pay federal income tax on “excess distributions” received from the foreign corporation...
The Internal Revenue Code (Code) contains more than 100 penalties. Used as a means to deter and punish unwanted taxpayer behavior, penalties may apply where a taxpayer files a return late, where a taxpayer pays tax late, or...
Federal income tax laws have allowed theft loss deductions since 1916. Surprisingly, however, there has been a great deal of confusion more recently on whether taxpayers may claim theft loss deductions. Much of this confusion...
Apparently not every IRS employee is on involuntary sabbatical. Yesterday the IRS issued Fact Sheet 2025-07 setting forth FAQs on the Employee Retention Credit (ERC) limitations enacted under the One Big Beautiful Bill...
I attended an informative panel discussion titled Challenging Revocations to Tax-Exempt Status at the ABA Tax Section’s Court Procedure and Practice Committee’s programming slot. Towards the end of the...
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