Just over a year ago, the IRS––armed with Inflation Reduction Act (IRA) funding and resources––announced how the increased funding would be put to use. Enforcement initiatives were aimed at corporate taxpayers and included “a large foreign-owned corporations transfer pricing initiative.” As part…
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…
With a flurry of IRS announcements regarding wealthy individuals and large partnerships, recent guidance on related-party basis transactions may have been easily overlooked. For many, this oversight may be a non-issue. But some unsuspecting taxpayers may find themselves ill-prepared to…
On June 18, 2024, the IRS modified the required information taxpayers must provide to the Service when submitting an I.R.C. § 41 research credit refund claim. The IRS had previously released a memorandum in October 2021 instituting five required pieces of information…
On June 28, 2024, the Supreme Court issued its long-awaited opinion in Loper Bright Enterprises et al. v. Raimondo, Secretary of Commerce, et al., overturning decades of judicial deference to agencies’ regulations. The Court overturned its forty-year-old precedent, Chevron U.S.A Inc. v….
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…
The Supreme Court released its eagerly awaited opinion in Moore v. United States yesterday. The majority opinion is carefully uncontroversial. The Court held that Congress may tax an entity’s undistributed income to either the entity or its shareholders or partners. For partners…
Background: Effects of Underfunding (2010–2021) On May 2, 2024, the IRS released its 2024 update to its strategic operating plan highlighting the impact of the Inflation Reduction Act (“IRA”). In the updated plan, the IRS notes that underfunding of the agency…
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…
On February 29, 2024, the Internal Revenue Service (“IRS”) announced a new effort targeting high-income non-filers who have failed to file federal income tax returns. (IR-2024-56, Feb. 29, 2024). Based on recent IRS pronouncements and our experience with prior non-filer…
