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

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 Respect to Certain Foreign Corporations, these taxpayers may have separate requirements to file an IRS Form 926, Return of a U.S. Transferor of Property

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 character that he knows that something is true. Tom Cruise’s character then exclaims “it doesn’t matter what I believe, it only matters what I can

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 for other reasons, as can often happen with family-run businesses.  Regardless of the reason, sometimes shareholders simply want out. 

Fortunately, the corporate income tax laws

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