The Internal Revenue Service (“IRS”) announced its plan to pursue criminal investigations into potential abuses of Puerto Rico’s Act 20/22/60 tax incentive programs. In a July 14, 2023, release, the IRS revealed that “[t]hanks to Inflation Reduction Act resources,” it has begun a criminal crackdown on Act 20/22/60 participants engaging in a ”[h]igh-dollar
In a case with far-reaching implications for tax jurisprudence, the U.S. Supreme Court will decide whether the controversial mandatory repatriation tax (MRT), created by the 2017 Tax Cuts and Jobs Act (TCJA), is unconstitutional under the 16th Amendment. The case is Charles G. Moore et al. v. United States, Case
By Garrett L. Brodeur Tax Notes Federal July 3, 2023 In a recent Letter to the Editor, Garrett L. Brodeur noted that several recent informal guidance documents on the tax treatment of cryptoassets suggest that the IRS is striving to provide meaningful direction, even under significant budgetary and resource constraints
The New York State Bar Association (NYSBA) Tax Section published Report No. 1478 on June 18, 2023 to provide comments on the IRS’s recent proposal (in Notice 2023-27) to tax certain NFTs as “collectibles” under section 408 of the Internal Revenue Code. As a member of the NYSBA Tax Section
Michael Sardar was quoted in a recent article in Yahoo Finance entitled “IRS gets major power to request private tax info after Supreme Court decision,” published on June 11, 2023. The article discusses the ramifications of Polselli v. International Revenue Service on taxpayer and third-party privacy. The article notes: Last month,
On June 21, 2023, Caroline D. Ciraolo discusses Bedrosian v. United States with the ABA Tax Section Administrative Practice Committee. Description: On June 20, 2023, the Supreme Court denied a petition for writ of certiorari in Bedrosian v. United States, Case No. 22-598, one of the longest running cases involving
On June 21, 2023, Andrew Weiner presents a webinar regarding the potential federal tax implications of Loper Bright Enterprises v. Raimondo and the possible repeal of Chevron deference to the ABA Tax Section Administrative Practice Committee. Description: Next term, the Supreme Court will consider in Loper Bright Enterprises v. Raimondo, Case No. 22-451,
On July 11, 2023, Don Fort provides opening remarks and will lead a panel of experts to open the summit titled “Robots and Robbers: Financial Crime Technology Summit,” a three-day virtual financial crime summit presented by The Financial Crime Academy. Description: Technology has made great advancements in the financial world,
