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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
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
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%.
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...
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.