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 September 16, 2022 Aretha Franklin Estate Settles with IRS

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

Articles September 16, 2022 Don’t Forget! 2020 Social Security Tax Deferral Payments are Due December 31st

The CARES Act, enacted in response to the COVID-19 pandemic, allowed employers to defer the payment and deposit of the employer’s share of Social Security tax. Those payments are coming due.

Articles September 16, 2022 When Does Owning or Managing Rental Real Estate Make You a “Real Estate Professional?”

This article examines the tests a taxpayer must satisfy in order to qualify as a real estate professional.

Articles September 16, 2022 IRS Has $80 Billion Coming Its Way: Expectations for Enforcement

The passage of the Inflation Reduction Act of 2022 gives $80B of additional funding to the IRS, with more than half of the funds allocated to enforcement efforts.

Articles August 18, 2022 An In-Depth Look at the IRS Criminal Investigation Voluntary Disclosure Practice

A thorough overview of the IRS Criminal Investigation Division’s (“IRS-CI’s”) current voluntary disclosure practice, designed for taxpayers to potentially avoid or mitigate prosecution for violating IRS and information reporting laws.

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.