Full disclosure, I’m an adopted Texan. I wasn’t born or raised in Texas, but my family and I moved from Washington, D.C. in 2007 and I have called it home ever since. Although this fact may, reasonably, color my views, it has been a remarkable place to watch economic growth and the adoption of the
It’s no secret that spouses, particularly in bad times, may hide things from one another. In fact, there are bodies of cases involving such marital behavior. However, we’ve gotten another recent reminder that such attempts can land you in hot water with the IRS, even if you were never out to hide anything from them
Artificial Intelligence continues to impact all industries as companies and individuals try and find the perfect balance between automation and sufficient oversight and monitoring. Tax reporting would appear, on its face, to be a prime candidate for the promises of efficiency achieved through AI’s streamlined review of large amounts of data and identification of potential
On Feb. 19, 2025, President Donald Trump issued Executive Order 14219, titled “Ensuring Lawful Governance and Implementing the President’s ‘Department of Government Efficiency’ Deregulatory Initiative.” The primary purpose of Executive Order 14219 is to direct federal agencies to review and rescind regulations that are deemed unconstitutional or that undermine national interests. The executive order
The Internal Revenue Service was aware of significant underreporting of cryptocurrency on tax returns and used one of its investigative tools (i.e., a John Doe summons) in 2016 to seek financial information on thousands of individuals, including James Harper. Harper sued in 2020, alleging unlawful access to his private financial information, and has been embroiled
A recent Tax Notes article highlighted the debate surrounding a Justice Department memo proposing the reassignment of Tax Division lawyers to U.S. attorneys’ offices across the country. Experts weighed in on the potential impact on tax enforcement, with some arguing that decentralization could weaken compliance efforts, while others saw opportunities for increased efficiency at the
Before the introduction of Bitcoin, around 2008, Wells Fargo included the phrase “Banking is necessary. Banks are not” in its 2004 annual report. The adoption of digital assets by traditional banks has been slow, primarily because of regulatory obstacles and a lack of legislative guidance that would help ease fears and reduce risks. Both
The Internal Revenue Service (IRS) recently issued Private Letter Ruling (PLR) 202504006, addressing several important estate and gift tax questions related to the division of a marital trust and the subsequent disclaimer of a surviving spouse’s interest in a portion of the trust. This ruling provides valuable insights into the tax treatment of trust divisions
In 2024, the IRS ramped up its focus on partnerships, including several actions before President Trump took office. However, with a new Treasury Secretary Scott Bessent confirmed, new IRS Commissioner Billy Long named but not yet confirmed, federal funding cuts, a federal hiring freeze, and employee reductions at both IRS and the Department of Justice
Two recent criminal tax cases, one crypto focused and one less so, show how digital assets are making their way into the normal legal process involving criminal tax enforcement.
The United States Department of Justice announced, in April 2024, that Roger Keith Ver, known by his followers as “Bitcoin Jesus,” was indicted on fraud