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

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

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

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

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

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 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