tax Advice Archive

TweetShareSharePin0 Shares In yesterday’s post Rochelle Hodes, Principal with Crowe LLP, provided background on BBA, emphasizing what makes its rules unique in tax procedure. Today’s post will briefly discuss two important BBA developments, the IRS’s Large Partnership Compliance Program and significant ABA Tax Section comments on proposed BBA regulations. Les The IRS is scheduled to

TweetShareSharePin0 Shares 0 Flares Filament.io Made with Flare More Info“> 0 Flares × When Congress passed the Bipartisan Budget Act of 2015 (BBA) in 2015 I rejoiced, thinking that my struggles with TEFRA had ended. My joy was short-lived, as many partnerships have years still subject to

TweetShareSharePin0 Shares Earlier this year I wrote a series of blogs in which I tried to think through the implementation of the newly enacted but temporary Advance Child Tax Credit (AdvCTC).  You can find those blogs here and here and here and here.  We are now several months into the delivery of the AdvCTC, and

TweetShareSharePin0 Shares Previously, I wrote about why it is IRC § 7602(e) wouldn’t keep the IRS from using information returns from banks to audit taxpayers. Let’s now suppose my analysis from the prior post is completely and entirely wrong and the IRS can’t use information returns in the way I suggest. What happens if the

TweetShareSharePin0 Shares In United States v. Sharpe, No. 2:20-cv-02490 (E.D. Pa. 2021) the court denied the taxpayer’s motion to dismiss an erroneous refund suit filed against her by the IRS.  The denial of the motion still leaves her with the opportunity to argue against the imposition of the erroneous refund provision on its merits.  It

TweetShareSharePin0 Shares The IRS on Thursday issued Notice 2021-56 to clarify the standards that a limited liability company (LLC) must satisfy to receive a determination letter recognizing it as tax-exempt under Sec. 501(c)(3). Generally, all the members of an LLC seeking tax-exempt status will have to be tax-exempt organizations themselves or governmental units. The LLC

TweetShareSharePin0 Shares Today we welcome back guest bloggers Alice Abreu and Richard Greenstein, Professors of Law at Temple’s Beasley School of Law in Philadelphia, with the third installment in our mini-series on IRS FAQ. On Friday, October 15, 2021, the IRS finally issued guidance addressing the controversial issue of taxpayer reliance on positions the agency announces