law Archive
IRS Announces It Will Start Following the Law (With Respect to Identifying Some Listed Transactions)
December 9, 2022
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TweetShareSharePin0 Shares Today’s guest post is from Jonathan Black, a senior associate in the Washington DC office of Caplin & Drysdale. Jon discusses the IRS’s latest efforts to address conservation easements, a topic that has generated considerable litigation and discussion on the blog. As Jon notes, the implications of the IRS’s actions this week may

The Supreme Court Reviews Penalties For Running Afoul Of FBAR Law
November 8, 2022
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TweetShareSharePin0 Shares Last week, the US Supreme Court heard oral arguments in a case over how much in penalties the US government can impose on citizens who fail to report to their foreign financial accounts of $10,000 or more. Beyond the immediate legal question, the case, Bittner v. the United States, raises important questions about

U.S. Congressman “Defied Property Tax Law” For Nearly a Decade
August 19, 2022
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TweetShareSharePin0 Shares U.S. Congressman Vicente Gonzalez of Texas has “defied property tax law” for nearly a decade by claiming two homestead exemptions. 54-year-old Democrat Gonzalez represents Texas’s 15th District in the United States House of Representatives. He was first elected in 2017. Now, it has come to light that the politician and his wife claimed two
Contract Law and Rejecting Offers in Compromise
July 25, 2022
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TweetShareSharePin0 Shares I apparently cannot stop writing about Offers and “deemed acceptance” under IRC § 7122(f). This is because I think it represents fertile ground for practitioners to help their clients, a way to hold the IRS accountable for getting things done in some semblance of a timely manner, and fix (or invalidate) an indefensible

Retirement tax planning issues if SECURE Act 2.0 becomes law.
April 13, 2022
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TweetShareSharePin0 Shares Whether you are a business owner or an employee, you will want to familiarize yourself with the SECURE Act 2.0 that was passed in the House of Representatives a couple of weeks ago. Though it still will likely face revision in the Senate, the bill has bipartisan support, and once it is passed

An Impasse Hits Businesses, A New Law Empowers Taxpaying Voters
March 22, 2022
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TweetShareSharePin0 Shares Powell: Larger interest rate hikes on the table. Fed Chair Jay Powell said yesterday the central bank could raise rates by greater incremental steps than the quarter-point increases the Fed kicked off last week. “We will take the necessary steps to ensure a return to price stability,” Powell told a business conference. His

Spain Start-Up Law Tax Proposal: Details & Analysis
December 15, 2021
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TweetShareSharePin0 Shares Three years after its initial announcement, Spain’s government has given a green light to the “start-up law” and sent it to parliament. The bill that could be approved by mid-2022 is part of the reform package that Spain and the European Commission agreed upon in order for Spain to receive the European Union

Pandora Papers: law firms must disclose clients’ names (like they’ve started doing in the US of all places)
October 7, 2021
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TweetShareSharePin0 Shares This blog post contextualises the new Pandora Papers leak. It explains the need for public beneficial ownership registries, it opposes the latest opinion by the EU Data Protection Supervisor on the matter, and it shows how to use recent US case law to get the names of enabler’s clients, regardless of professional secrecy.

What Should the President Do When Debt Limit Inaction Forces Him To Violate The Law?
September 29, 2021
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TweetShareSharePin0 Shares When Congress increases spending and cuts taxes then fails to extend the nation’s debt limit, it effectively orders the president to run deficits while prohibiting him from borrowing the money needed to support those deficits. It requires the executive to defy the laws of logic and arithmetic, as well as the law of
The Law Does Not Forbid a Helpful Internal Revenue Policy
September 23, 2021
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TweetShareSharePin0 Shares Commenter in chief Bob Kamman returns with a colorful story following up on yesterday’s topic of jeopardy assessment. The Fumo case, of course, is small potatoes. If you want a real jeopardy assessment involving a real politician, you have to go back to March 13, 1925, when Internal Revenue assessed James Couzens, United