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
By Don Fort Bloomberg Tax December 18, 2023 The Covid-19 pandemic brought about a once-in-a-generation health crisis, also creating a surge in fraud. Earlier this month, the IRS’s Criminal Investigation Division unveiled a conspicuously high conviction rate—over 98% for the more than 300 Covid-19 fraud
By Ian Buksunski and Abigail Burke The CPA Journal September/October 2023 The article discusses upcoming changes to small-business reporting requirements enacted as part of the Corporate Transparency Act, including who is required to report under the law, what information must be included, and the penalties
By Christopher M. Ferguson CCH Journal of Tax Practice & Procedure Fall 2023, Volume 25, Issue 3 Over the past three and a half years, countless businesses have availed themselves of the Employee Retention Credit (“ERC”), a tax credit intended to incentivize businesses to retain
By Caroline Rule ABA Tax Times Volume 42, No. 4 – Summer 2023 In the next Supreme Court term, the Justices will hear argument on whether the Mandatory Repatriation Tax (MRT), violates the Sixteenth Amendment. Depending on how the Court decides this issue, the case
