Tax Controversy and Dispute Resolution Spotlight

Taxpayers who seek the tax benefits of nonpassive income/loss characterization should keep complete, accurate and contemporaneous records of the hours worked in each activity.

Unlike the Paycheck Protection Program and Economic Injury Disaster Loan programs, the ERC was extremely complex. The United States Department of Justice and the IRS Criminal Investigation Unit have been focusing on ERC fraud with the funding from th…

U.S. citizens who owe delinquent taxes not only face the risk of enforcement actions such as liens and levies, but they can also be prevented from traveling internationally. This article discusses who the passport restriction applies to, as well as t…

This article focuses on Chief Counsel Advice memoranda on the reporting of cryptocurrency transactions, including whether taxpayers may claim a loss deduction for decreases in the value of cryptocurrency and the requirements for claiming a deduction …

This article features insight into a number of areas of IRS interest involving partnerships and international tax penalties where we may get some clarity in the coming year.

The CARES Act authorized the SBA to issue EIDL to certain COVID-19 affected businesses and eligible small business owners. The payment deferral period has begun to sunset, and payment is becoming due for borrowers who took loans out early in the pand…

This article offers a view of the Accelerating Charitable Efforts Act, introduced into Congress, which proposes several changes to the tax consequences of donor-advised funds.

The Tax Court’s ruling in Treece Financial Services gives taxpayers more leverage in negotiating with the IRS about the application of these programs, as well as offering due process to taxpayers who are denied participation in the programs by the IR…

The estate of Aretha Franklin has settled its long-standing debt with the IRS following negotiations.