The U.S. Treasury Department faces a complex task in enforcing its proposed digital asset reporting rules on foreign trading platforms. The regulations, introduced in late August, primarily address domestic transactions…


Is Your Partnership Ready for IRS Audit Initiatives? Because the IRS is Coming!
On September 8, 2023 the IRS announced a sweeping effort to focus enforcement efforts on high-income individuals, partnerships, and corporations. On September 20, 2023 the IRS announced that it will…
An interesting recent Tax Court decision seems to indicate that taxpayers have clear autonomy with regards to judicial review as well as retracting judicial review of “seriously delinquent tax debt.”…
The tax community is currently embroiled in a heated debate over proposed IRS guidelines concerning timing provisions, the broad scope of individuals eligible to approve penalties and exemptions related to…
For some time, the IRS has cautioned taxpayers about filing false or fraudulent ERC claims. More recently, on September 14, 2023, the IRS issued a News Release, IR-2023-169, indicating…

IRS Announces New Compliance Efforts Aimed at High-Income Taxpayers, Partnerships, Digital Assets, FBARs and Labor Brokers
On September 8, 2023, the IRS announced a multitude of compliance initiatives aimed at high-income taxpayers, partnerships, digital assets, FBARs and labor brokers. According to the announcement, the IRS has…

IRS Sanctioned for Bad Faith on Supervisory Approval of Penalties While Proposed Regulations on the Same Issue are Pending
A hearing is scheduled for September 11, 2023 for interested persons and organizations to provide testimony on proposed regulations on the timing and approval process for penalties. Section 6751(b) provides…

Joshua Smeltzer Quoted by Law360 on Proposed Broker Rules for Digital Asset Transactions
Providers of digital asset services would be subjected to tax reporting regulations akin to those governing brokers of securities and analogous financial instruments, as outlined in the inaugural set of…
The FATCA Data Haystack Remains Just That
The Foreign Account Tax Compliance Act (FATCA) has resulted in a massive influx of financial information to the IRS over the past 13…
For some time, promoters have shopped around an arrangement known as a “section 643(b) trust,” known alternatively as a “non-grantor, irrevocable, complex, discretionary, spendthrift trust.” On August 9, 2023, IRS…

IRS Chief Counsel Issues GLAMon ERC Supply-Chain Disruption Eligibility
Section 2301 of the CARES Act, as amended, permits employers to claim employee retention credits (“ERCs”) if they meet certain requirements. Under one of those requirements, an employer may claim…

IRS Characterizes Monetized Installment Sales as Listed Transaction in Proposed Regulations
Monetized installment sale transactions (“MISTs”) have been on the IRS’s radar for some time. On May 7, 2021, IRS Chief Counsel issued an advice memorandum, contending such transactions were “problematic”…

Federal Courts Mixed on Whether the 90-Day Tax Court Petition Deadline Under Section 6213 is Jurisdictional
Deadlines are important, particularly in federal tax law. Many taxpayers are aware, for example, of the significant penalties that the IRS may impose upon them for failure to timely file…
About the Gray Reed Tax Team
Gray Reed’s Tax Department provides experienced legal counsel to clients on all matters arising from international, federal, state and local tax laws. Our areas of expertise and services include ad valorem, asset protection, civil and criminal tax litigation, consulting, controversy, corporate, ERISA, estate planning, franchise, income tax, state tax, international, IRS audit, mergers and acquisitions, partnership, personal, planning, federal tax credits related to renewable energy and research and development expenses, property, real estate, reorganizations, and white-collar defense.