Intellectual property (“IP”) is hugely important to businesses. Given that importance, IP owners must occasionally litigate against the unauthorized use of their technology. The costs of such litigation and appurtenant settlements implicate a host of federal income tax issues. Some IP litigants do not consider those tax issues at all, while others aggressively overplay their

Many taxpayers have art collections. However, the art collections of some high-net-worth individuals, family offices, and business taxpayers may draw the unwanted eye of the IRS. With the increased focus on auditing high-income taxpayers, large partnerships, and using increased staff and artificial intelligence will almost certainly increase the number of cases involving artwork. At the

We have previously spoken about monetized installment sales (“MISTs”) on Dollars & Sense.  According to the IRS, these structures typically seek to defer gains associated with the sale of an appreciated asset through the use of an intermediary.  In recent years, the IRS has scrutinized taxpayers’ usage of MISTs, even proposing regulations that would make

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 IRS recently issued a press release regarding its “continuous efforts to combat dubious Employee Retention Credit (ERC) claims” to announce an initial round of over 20,000 notification letters of disallowed ERC claims. This initial round of notices is addressing two “problem areas” the Service has identified in their ongoing review of ERC claims: 1)