Gray Reed Partners Austin Carlson and Joshua Smeltzer will be speaking in a webinar hosted by the CalCPA. CalCPA is the largest state CPA society in the nation, representing and supporting certified public accountants and related professionals in California.
Scheduled for August 14, 2024, at 2 pm CST the webinar will provide an update on
On June 20, 2024, the Supreme Court released its opinion in Moore et ux v. US, authored by Kavanaugh, decided by 6-3 vote and marking a rare instance for the Court to interpret the 16th Amendment, upholding the constitutionality and application of the so-called “Mandatory Repatriation Tax” [MRT] under Article I, §§8 and
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
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
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
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
The Tax Court can be an unusually cruel place when it comes to deadlines. This is what a recent taxpayer found out in a Tax Court decision that denied their challenge of an over $4.6 Million dollar tax bill asserted by the IRS. See Nguyen v. Comm’r, T.C. Memo 2023-151. The taxpayers received
Recently, in a criminal case involving a physician who hired an accountant to prepare and submit certain tax forms to the IRS on her behalf, the court denied attorney-client and work-product privilege claims and ordered the accountant to testify at the criminal trial. See United States v. Barrett, No. 22-cr-00071 (M.D. Louisiana). One of