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

New rules proposed by the U.S. Treasury Department relax disclosure requirements for certain offshore retirement accounts but leave classification questions unresolved. The guidance raises the reporting threshold for overseas retirement trusts, exempting more accounts than the 2020 procedure. However, uncertainty remains about classifying certain foreign retirement plans. Additionally, questions may arise about classifying transfers from

Gray Reed Partner and Dollars & Sense Editor Joshua Smeltzer will be speaking at Convergence 2024, TXCPA Dallas’ premier continuing professional education event.

Scheduled for May 10, 2024, at the Sheraton Dallas Hotel (Downtown), Joshua’s session “Protecting Confidentiality: The Crucial Intersection of Attorney-Client Privilege and CPA Practice” will provide invaluable insights into navigating the complexities

The IRS’s ERC voluntary disclosure program has drawn concern from tax attorneys due to uncertainty around entering into the program and still being subjected to criminal prosecution.  Extensive disclosure is required as part of the program, however, the IRS does not provide any assurances related to the possibility of post-disclosure investigations, which raises significant questions

In recent years, U.S. taxpayers have engaged in “Malta pension plans,” utilizing these arrangements to contribute appreciated assets and claim tax exemptions under the U.S.-Malta tax treaty. Nevertheless, the U.S. government has responded with measures, including the Competent Authority Arrangement (CAA) and proposed regulations, aiming to restrict treaty benefits due to suspected misuse and potential

As the price of bitcoin rises, it is dominating the discussion regarding the future of cryptocurrencies, other digital assets and blockchain technology. Although the bitcoin price is a good thing, there is much more to be excited about regarding blockchain technology and digital assets in 2024.

Gray Reed Partner Joshua Smeltzer, who co-leads the

FTX is embroiled in a $24 billion tax dispute with the Internal Revenue Service (IRS) in its bankruptcy case. The IRS claims FTX owes this amount in unpaid taxes, but FTX says the claim has “no relation to reality” (Law360, 2023). An estimation hearing has been ordered by the bankruptcy judge to determine the validity

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 automated penalty calculations.

At the heart of the controversy lies Section 6751(b), which mandates that the immediate supervisor of a revenue agent must personally provide