Tax Controversy and Dispute Resolution Spotlight

Content providing insight and guidance to both corporate and individual taxpayers related to recent tax cases, enforcement actions, and IRS and Department of the Treasury initiatives.

Articles December 09, 2021 Discovery of a Delinquent International Information Return – What Do You Do?

The potential for extraordinarily high tax penalties if a taxpayer fails to timely file complete and accurate required international information returns is significant – at the same time, there are ways to remedy a missed filing requirement while red…

Articles December 09, 2021 More Scrutiny of Research Credit Refund Claims Expected Following IRS Memo

This article examines the IRS Office of Chief Counsel’s recently issued a memorandum detailing the information required where a taxpayer files a refund claim for the research credit under IRC Sec. 41.

Articles December 07, 2021 Extreme Delays in Processing Form 1045 Refunds

The IRS continues to experience delays in its operations. This article takes a look at the current state of IRS efforts to remediate the concerns.

Articles December 06, 2021 IRC Sec. 7525 Federally Authorized Tax Practitioner Privilege of Confidentiality

IRC Sec. 7525, generally effective for communications made on or after July 22, 1998 between a taxpayer and a “federally authorized tax practitioner,” provides for the uniform application of confidentiality to taxpayer communications with professiona…

Articles September 09, 2021 Court Agrees on IRS Assessment of Double Penalties for the Failure To Report the Ownership and Distributions from a Foreign Trust

This article takes a look at what this means for U.S. owners and beneficiaries of foreign trusts.

Articles September 09, 2021 Syndicated Conservation Easement Transactions

This article examines IRS and Treasury efforts to inform taxpayers and tax practitioners about their concern whether the structure and form of certain syndicated conservation easement transactions constitute bona fide charitable contribution deductio…

Articles September 02, 2021 IRS Resuming Normal Collections Activities

The IRS recently announced that their remaining COVID-19-related relief measures will end this summer, and they will return to normal collections procedures. This article explains what that means for taxpayers, and how to most effectively handle IRS …

Articles September 02, 2021 Affordable Care Act Mistakes Can Result in Costly IRS Penalties to Employers

What mistakes to avoid that can otherwise result in costly IRS penalties from the Affordable Care Act.

Articles August 23, 2021 Outdated “Responsible Party” Information May Slow Down Your Tax Refund

In an effort to combat identity theft and fraud security issues, the IRS is urging corporations, partnerships, trusts and estates and other entities with EINs to update their information if there has been a change in the responsible party or contact …