In November 2025, the United States Court of Federal Claims (CFC) decided Kwong v. United States, No. 23-267, 179 Fed. Cl. 382 (Fed. Cl. 2025), an important case which addressed taxpayer concerns about the duration of mandatory extension periods under…
In March of 2020, in response to the COVID-19 pandemic, Congress enacted the Coronavirus Aid, Relief, and Economic Security (“CARES”) Act.[1] In addition to the PPP program for small businesses, Section 2301 of the CARES Act allowed for a credit…
The IRS has brought a slew of cases against hedge funds and private equity firms in recent years challenging funds’ positions that the use of limited partners in partnerships excludes limited partner income from self-employment tax. Three hedge funds have…
Tax Court Clarifies SECA Tax Applicability to Active Limited Partners Last month, the Tax Court issued another decision addressing the meaning of limited partner for private equity and hedge fund managers, once again subjecting the managers to Self-Employment Contributions Act…
For those of us justifiably dissatisfied with this season of House of the Dragon, recent ERC action may lend some much-needed excitement—some might say gore? Last month, the IRS issued nearly 30,000 denial letters to taxpayers for ERC claims it…
The IRS has finally come up for air to offer insight into its months-long “review period” of pending Employee Retention Credit (“ERC”) claims. On June 20, 2024, the agency announced that it will begin issuing payments on roughly 10 to…
In an important decision for assessable international penalties, last week the D.C. Circuit reversed a Tax Court decision holding that the IRS could not assess international information return penalties without offering the taxpayer the opportunity to contest them through deficiency…
