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May 2, 2023
IRS proposed regulation identifies certain micro-captive transactions as listed transactions and certain other micro-captive transactions as transactions of interest. Notice 2023-34, which provides that convertible virtual currency is treated as property for federal tax
April 13, 2023
USDT proposed regulations identifying certain micro captive transactions as listed transactions or transactions of interest for purposes of disclosure rules for taxpayers and material advisors. Proposed regulations in response to taxpayer victory in CIC Services LLC v. IRS
January 9, 2023
The January 2023 Section 7520 rate for use with estate planning techniques such as CRTs, CLTs, QPRTs and GRATs is 4.6%, a decrease from the December 2022 rate of 5.2%.
December 14, 2022
Today's guest post is from Jonathan Black, a senior associate in the Washington DC office of Caplin & Drysdale. Jon discusses the IRS's latest efforts to address conservation...
December 9, 2022
Following defeat in Tax Court cases of Administrative Procedure Act, IRS issues proposed regulations identifying syndicated conservation easement transactions as listed transactions. This shows the IRS is taking a proactive approach in addressing the APA challenges.
December 9, 2022
On December 6, 2022, less than a month after its historic loss in the Tax Court in Green Valley Investors LLC v. Commissioner, 159 T.C. 5 (2022), the IRS released Announcement 2022-28...
August 26, 2021
A “qualified amended return” is an amended tax return that, if properly filed before a taxpayer is “on the IRS’s radar,” protects a taxpayer against accuracy-related penalties—in...
July 30, 2021
Kiyoshi Ota/Bloomberg News REGISTER NOW Given their popularity and widespread use, people rarely think of IRAs as “tax shelters.” But truth be told, that’s exactly what an individual retirement account is: a legal tax shelter. However, in order to reap the benefits that traditional IRAs and Roth IRAs provide, taxpayers must comply with an assortment of rules. Such rules include limitations on the amount of money that can be contributed to IRAs each year, requirements related to the distr...