Yum! Brands Challenges IRS on "Killer B" Regualtions... [ read ]
In our latest blog post, Nick S. Pegelow examines Yum! Brands' high-stakes case regarding "Killer B" anti-abuse regulations, international reorganizations and when a "B Reorg" triggers a US tax bill.
Taxpayer Advocate Convinces IRS to Remove Willfulness Requirement for Voluntary Disclosure Program... [ read ]
The Taxpayer Advocate convinced the IRS to ‘undo' a recent, highly criticized change to the Voluntary Disclosure Program that required the taxpayer's admission of willfulness prior to participation.
Proof That Dotting the I's and Crossing the T's Keeps the IRS at Bay... [ read ]
In our latest blog post, Joel Crouch discusses the case Estate of Barbara Galli v. Commissioner, and how every detail counts in tax-sensitive transactions.
Strategic Considerations for Tax-Exempt Status Revocation IRS Examinations... [ read ]
In our latest blog post, Jeffrey M. Glassman explores the high-stakes of IRS examinations that can lead to an organization's tax-exempt status being revokes.
Court Finds in Favor of Taxpayer on TurboTax Form 3520 Penalty Defense... [ read ]
In our latest blog post, Matthew Roberts analyzes Huang v. United States, a recent case in which a taxpayer challenged IRS Form 3520 penalties.
Foreign Grantor Trusts & U.S. Taxes: Understanding Section 679... [ read ]
In our latest blog post, Matthew Roberts explores the complex tax implications of foreign grantor trusts under Section 679 with U.S. beneficiaries.
Refund Litigation Continued: Types of Cases... [ read ]
This blog builds on prior posts concerning refund litigation. This blog explores the types of tax refund cases that can be brought in the U.S. district courts and the U.S. Court of Federal Claims.
Tax Residency: Key Differences Between the U.S. Income and Transfer Tax Rules... [ read ]
The application of U.S. tax laws often turns on the meaning of "residency." Although U.S. citizens and residents are subject to federal income taxes on their worldwide income, non-residents who are not U.S. citizens ("Foreign Persons") are generally not unless the income has a nexus to the U.S. Under the U.S. income tax regime, individuals may establish residency through their physical presence in the U.S.
A Sample of Tax Cases in Federal District Court: Criminal vs. Civil... [ read ]
Most federal tax disputes are resolved administratively or in the United States Tax Court, where taxpayers might challenge IRS determinations in a specialized forum that requires no prepayment of the disputed tax. But not all tax cases follow that path.
Late-Filing Penalties, Reasonable Cause, & Boyle... [ read ]
There are more than 100 penalties in the Internal Revenue Code. Each penalty varies in scope, but a common defense for almost all of them is "reasonable cause." Where this defense applies, the IRS can't impose penalties.
