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 June 08, 2022 Three Tax Pitfalls for Foreign Owners of U.S. Real Property

Foreign investment in U.S. real estate can be complicated from a tax perspective, including potential U.S. estate tax exposure as well as income and information reporting obligations.

Articles June 08, 2022 Noncash Charitable Contributions

Taxpayers are entitled to income tax deductions equal to the fair market value of their charitable contributions – however, reporting noncash contributions can be difficult.

Articles June 06, 2022 Supreme Court Expected to Settle FBAR Penalty Circuit Split

The Supreme Court has been asked to weigh-in regarding the amount of penalties that can be assessed by the IRS per year for a non-willful failure to report offshore accounts, following a split between the Fifth and Ninth Circuit Courts of Appeal.

Articles March 10, 2022 Proof-of-Stake Blockchain: Taxable or Not?

The disclosure of virtual currency transactions is required on all individual income tax returns, but limited guidance exists today on the tax treatment of the breadth of virtual currency transactions that have emerged.

Articles March 10, 2022 IRS’s Legal Authority for Requesting Electronic Accounting Records and Software

This article discusses the legal authority the IRS has to request any books, papers, records, or other data, including electronic accounting records and software.

Articles March 07, 2022 Failed to Disclose Foreign Income/Assets? Streamlined Filing Procedures May Be the Answer.

This article focuses on Streamlined Foreign Offshore Procedures that allow qualifying U.S. citizens or lawful permanent residents, or estates of U.S. citizens or lawful permanent residents, with undisclosed foreign income, investments, or accounts, t…

Articles March 07, 2022 IRS Continues Targeting of Micro-Captive Insurance Companies

The IRS has stepped up examinations of micro-captive insurance arrangements in recent years, claiming that such arrangements are often abusive. This content focuses on specific cases and IRS response.

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.