Kostelanetz LLP Partner Megan L. Brackney is calling for an end to IRS foreign gift penalties, arguing that the current law is inefficient and punitive to lower- and middle-income taxpayers with foreign relatives. In an op-ed for Bloomberg Tax, Ms. Brackney addresses concerns raised by
by Robert McLeod The CPA Journal May/June 2024 To reduce unnecessary costs, businesses strive to minimize their tax liabilities. Employment taxes, particularly the employer’s share of Social Security and Medicare taxes under FICA, may represent a significant portion of a company’s tax burden. On the
By Christopher M. Ferguson Bloomberg Tax August 1, 2024 The US Supreme Court’s ruling overturning Chevron deference, as well as the IRS’s own policies, suggest the IRS may be employing a harsh and legally unsustainable standard in assessing the merits of employee retention credit claims. If true,
By Daniel C. Davidson ABA White Collar Crime Committee Newsletter July 2024 Earlier this year, the Department of Justice (“DOJ”) and Federal Trade Commission (“FTC”) jointly announced updated language in the agencies’ documents requests (such as preservation letters and grand jury subpoenas) “to address the
In Charles G. Moore v. United States (No. 22-800), petitioners challenged Congress’s authority to tax unrealized gains under the Sixteenth Amendment. The tax at issue was the Mandatory Repatriation Tax (MRT), which is a one-time tax on accumulated but undistributed foreign earnings that was included in the
Many nonprofits that were affected by the COVID-19 pandemic have financially benefited from claiming the Employee Retention Credit (ERC). But the ERC has become the source of considerable notoriety over the last several years and is now the focus of significant government enforcement activity. Originally
In a National Law Journal article published on June 26, 2024, Jay R. Nanavati and Nikhil Lahiri explain how a recent privacy law surrounding private jet flights will not prevent the IRS from following through on its pledge to scrutinize private aircraft usage by “large corporations, large
By Megan L. Brackney and Vishan Chaudhary The CPA Journal January/February 2024, Featured Columns, Taxation In their article for The CPA Journal, Megan L. Brackney and Vishan Chaudhary outline an approach for tax advisors responding to clients who ask for advice or assistance on what
By Michael Waalkes The CPA Journal January 2024 Due to recent taxpayer-favorable court decisions requiring the Department of the Treasury to use formal notice-and-comment procedures under the Administrative Procedure Act (APA), the process by which the IRS publicly identifies listed transactions has undergone significant changes.
By Abigail Burke ABA Tax Times Volume 43, No. 1 – Fall 2023 This article summarizes the tips for effective Tax Court advocacy presented in the ABA’s virtual CLE presentation titled “Making Your Case in Tax Court: Advocacy Tips.” […] Click here for the full
