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 no longer automatically assess penalties for foreign gifts and inheritances reported on Form 3520 and will start reviewing reasonable cause statements for late-filed Forms 3520
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 to funnel much needed money to eligible businesses that retained, rather than laid off, their employees. At first blush, the qualifications for the ERC seem…
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 founder and former CEO, Sam Bankman-Fried, is currently in custody alongside Sean “Diddy” Combs at the Metropolitan Detention Center in Brooklyn. These enforcement actions highlight…
Gray Reed Tax Planning Partner Austin Carlson to Speak on 1031 Exchanges (Webinar)
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 10 am CST, the webinar will provide a top ten rundown of tips and traps related to 1031 exchanges. During the webinar, Austin will discuss:…
Gray Reed Partners Submit Comments on Proposed Treasury Regulations
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 proposed regulations on foreign trusts and gifts, including applicable information return reporting. Joshua serves as a Council Member of the Tax Section and Vice Chair…
Gray Reed Tax Attorney Quoted by Law360 on Continued ERC Moratorium
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. With no clear end in sight for the moratorium, some employers are now considering litigation to obtain their ERC refund.
Law360 covered the topic on…
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 Corporate Transparency Act and the moratorium on employee retention tax credits. Concurrently, the U.S. Supreme Court will review a case involving a defunct transportation company…
Gray Reed Partners Austin Carlson and Joshua Smeltzer to Speak on International Tax Enforcement Update
Gray Reed Partners Austin Carlson and Joshua Smeltzer will be speaking in a webinar hosted by the CalCPA. CalCPA is the largest state CPA society in the nation, representing and supporting certified public accountants and related professionals in California.
Scheduled for August 14, 2024, at 2 pm CST the webinar will provide an update on…
Gray Reed Tax Partner Discusses Mandatory Repatriation Tax Ruling on Podcast
On June 20, 2024, the Supreme Court issued a narrow ruling upholding the constitutionality of the transition tax in Moore v. United States. The Court did not address issues related to pass-through taxation, realization events, and a potential future wealth tax. The ruling preserves the tax laws related to foreign corporations that were ushered…
Gray Reed Files Amicus Briefs Challenging SEC’s “Regulation by Enforcement” Approach
Gray Reed has recently filed two significant amicus briefs challenging the Securities and Exchange Commission’s (SEC) controversial “regulation by enforcement” approach, particularly in emerging technology sectors.
The first brief was filed on behalf of the Texas Blockchain Council and the AI Innovation Association in the ongoing SEC “gag order” case before the 9th Circuit Court…