In recent headlines, an Ohio woman has brought a refund suit in district court, seeking recovery of taxes and withholding from the IRS that she claims were based on the…
In a bench opinion dated September 27, 2024, the Tax Court sustained a Notice of Federal Tax Lien but not the proposed levy against Daugerdas, a convicted tax shelter promoter…
Matt Roberts’ “IRS Announces Sweeping Changes To Form 3520 And 3520-A Penalty Rules” Article in Forbes
The IRS has announced a significant shift in its approach to penalties for late-filed Forms 3520 and 3520-A, particularly concerning foreign gift and inheritance reporting. Effective immediately, the IRS will…
Matt Roberts’ Article “As ERC Lawsuits Grow, IRS Touts Progress In Claims Processing” in Forbes
The employee retention credit (ERC) has been a thorn in the IRS’ side for some time. Enacted during the COVID-19 pandemic, Congress originally designed the ERC as a means…
Matt Roberts’ Article “IRS Files Criminal Charges Against Participant In Abusive Trust Scheme” in Forbes
In recent years, the government has continued to ramp up its investigatory efforts concerning trust arrangements that it deems abusive for tax purposes. These investigations have included so-called “section…
Gray Reed Partners Chris Davis and Joshua Smeltzer’s Crypto Article Featured in Bloomberg Leading news
The Securities and Exchange Commission (SEC) has recently disclosed two settled enforcement actions against Prager Metis CPAs, an audit firm linked to FTX, the now-defunct crypto trading platform. The firm’s…
Gray Reed Tax Planning Partner Austin Carlson will be speaking about 1031 exchanges on a webinar hosted by ROI-Muse’s Commercial Investors & Brokers Alliance.
Scheduled for September 20, 2024, at…
U.S. persons who make outbound investments in foreign corporations often have thorny federal reporting obligations. In addition to the commonly filed IRS Form 5471, Information Return of U.S. Persons With …
In one of my favorite legal movies, A Few Good Men, the lack of evidence on a particular point is brought up when Demi Moore’s character says to Tom Cruise’s…
Disagreements happen. In the corporate context, one or more shareholders may share a different vision for the company than the other shareholders. Or, there may be acrimony amongst the shareholders…
Through their leadership positions with the State Bar of Texas Tax Section, Gray Reed partners Joshua Smeltzer and Matt Roberts recently submitted comments to the Treasury and IRS related to…
With the IRS ERC moratorium still in effect, employers are carefully considering their options including litigation. Recently, the IRS indicated it was prioritizing low-risk claims while flagging others as problematic.
Joshua Smeltzer Quoted by Law360 on Top Federal Cases to Watch in the Second Half of 2024
In the upcoming months, the U.S. Treasury and the IRS will be defending regulations aimed at curbing what they deem abusive tax practices, such as the economic substance doctrine, the…
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.