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

On September 8, 2023, the IRS issued a News Release suggesting that FBAR compliance investigations and audits would heat up in the near future.  For those unfamiliar with FBARs, federal law requires United States persons to file an FBAR annually if such persons have a financial interest in or signature or other authority over foreign

Recent Government actions suggest that third-party promoters and potentially hundreds of taxpayers may be entering into abusive trust arrangements aimed at unlawfully eliminating or deferring federal income taxes. Specifically, on August 9, 2023, IRS Chief Counsel issued a Memorandum on a trust arrangement known as a “section 643(b) trust.” In the Memorandum, Chief Counsel urged

 On remand for re-calculation of 4 errors in deficiency amounts, concerning years 2003, 2004, 2005, and 2006, the Tax Court entered final revised decisions based on the Commissioner’s twice-revised Rule 155 computations.

During the Larkins’ appeal, the Commissioner acknowledged four errors affecting the amounts of the deficiencies, additions to tax, and penalties. The court of

For some time, the IRS has cautioned taxpayers about filing false or fraudulent ERC claims.  More recently, on September 14, 2023, the IRS issued a News Release, IR-2023-169, indicating that it would no longer process ERC claims from September 14, 2023, through “at least” December 31, 2023.  Significantly, this only relates to new ERC