In recent years, the IRS has focused its attention and resources on large partnerships. In 2021, the agency launched an initial phase of its Large Partnership Compliance (LPC) program. Under this program, the IRS identified and initiated audits of some of the largest and most complicated partnership tax returns. Later, the agency used artificial intelligence

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

On March 25, 2024, the IRS issued proposed regulations (REG-108761-22) which, if finalized, would identify certain CRATs as listed transactions.  For those unaware of the listed transaction rules, such a designation would mean that taxpayers and material advisors who participated in these CRATs would have to comply with lengthy disclosure statements or risk

Intellectual property (“IP”) is typically monetized either by sale or (royalty generating) license agreements. The Code[1] often allows sales to be taxed at preferential capital gains rates[2] while simple royalties are ordinary income.[3] At present the maximum capital gain versus ordinary income rate differential for non-corporate taxpayers – without more[4]

In addition to being developed in-house, intellectual property (“IP”) can obviously be acquired from third parties. IP acquisitions may be more germane now than in the recent past as developers race to create and monetize artificial intelligence (“AI”) tools.  But, while AI platforms might be the shiniest and most interesting objects in the current IP

Intellectual property (“IP”) development can cost millions of dollars so cost recovery timing can be financially material. General tax principles typically require that expenses associated with creating assets having useful lives lasting longer than the current tax year are capitalized.  However, IP as an asset class has several statutory cost recovery possibilities (§§ 162, 167

In a recent Tax Court decision, the court reviewed the activities of the Huffman family as it pertained to corporate dealings involving the family aviation business (Infinity Aerospace Inc. which the court refers to by its previous name of “Dukes”), making findings with regards to reasonable cause, valuation of personal goodwill, correct reporting of capital

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