KPMG: Administration releases FY 2024 budget recommendations with tax proposals (Mar. 9, 2023)

KPMG has reported that the Biden Administration has released its FY 2024 Budget proposals, which contain significant tax proposals. The KPMG post begins as follows: The Office of Management and Budget (OMB) today released and transmitted to Congress its budget recommendations for fiscal year (FY) 2024. This release [PDF 9.8 MB] (182 pages) includes the budget message of the … Continue reading KPMG: Administration releases FY 2024 budget recommendations with tax proposals (Mar. 9, 2023)

TaxNotes – Andrew Blair–Stanek, Nils Holzenberger, Benjamin Van Durme: Shelter Check: Proactively Finding Tax Minimization Strategies via AI (December 27, 2022)

Andrew Blair-Stanek, Nils Holzenberger, Benjamin Van Durme have published an article on Tax Notes, titled “Shelter Check: Proactively Finding Tax Minimization Strategies via AI.” The article begins as follows: In Peracchi,1 the Ninth Circuit addressed what basis a taxpayer had in a note in which he was the debtor. At the end of the opinion, … Continue reading TaxNotes – Andrew Blair–Stanek, Nils Holzenberger, Benjamin Van Durme: Shelter Check: Proactively Finding Tax Minimization Strategies via AI (December 27, 2022)

Nina Olson (Procedurally Taxing): Racial Disparities in IRS Audits (January 31, 2023)

Nina Olson, Executive Director of the Center for Taxpayer Rights, has made available for download her article, “Racial Disparities in IRS Audits,” published in the Procedurally Taxing blog. The abstract is as follows: Following up on Les’ post yesterday about the upcoming symposium on race and taxes, I want to draw our readers attention to … Continue reading Nina Olson (Procedurally Taxing): Racial Disparities in IRS Audits (January 31, 2023)

The Tax Adviser: New online portal available for businesses to file Forms 1099 (January 25, 2023)

The Tax Adviser has published an article, “New online portal available for businesses to file Forms 1099,” which discusses The Information Returns Intake System or “IRIS”, an online portal available for submitting Forms 1099. The article begins as follows: A new online portal where businesses can file Form 1099 series information returns for free is … Continue reading The Tax Adviser: New online portal available for businesses to file Forms 1099 (January 25, 2023)

KPMG Report:  Year-in-review list of U.S. federal tax developments for 2022 (January 31, 2023)

KPMG has made available for download their article, “Year-in-review list of U.S. federal tax developments for 2022 ”, which includes an easy-to-use list of many 2022 U.S. federal tax developments. The abstract is as follows: KPMG LLP has compiled an easy-to-use list of many recent federal tax developments to help users quickly identify what happened in … Continue reading KPMG Report:  Year-in-review list of U.S. federal tax developments for 2022 (January 31, 2023)

Bloomberg Tax: From Crypto to Sales Taxes, a Look at State Taxation for 2023 (December 19, 2022)

Bloomberg Tax presents in-depth observations into four categories of state and local taxation for the upcoming 2023 fiscal year that litigators should seek to direct their focus toward. The article begins as follows: Gary C. Bingel of EisnerAmper previews some of the areas of state and local taxes that are most ripe for guidance and … Continue reading Bloomberg Tax: From Crypto to Sales Taxes, a Look at State Taxation for 2023 (December 19, 2022)

AICPA: PFP Digest (December 20, 2022)

AICPA has published their PFP Digits for December 2022. The articles begin as follows: TOP STORY What does the FTX collapse mean for crypto?The collapse of FTX and several cascading bankruptcies across the cryptocurrency market have called the future of digital assets into question. The crash will likely weed out overhyped currencies and companies and … Continue reading AICPA: PFP Digest (December 20, 2022)

Megan L. Brackney (Procedurally Taxing): The IRS’s Aggressive Enforcement Of Foreign Information Return Penalties Has Created Ethical Dilemmas For Practitioners (Part 2) (December 8, 2022)

Megan L. Brackney, of Kostelanetz LLP,  has made available for download her article “The IRS’s Aggressive Enforcement Of Foreign Information Return Penalties Has Created Ethical Dilemmas For Practitioners (Part 2)”, published on the Procedurally Taxing blog. The abstract is as follows: In yesterday’s post, I discussed some common penalties for failing to file foreign information returns … Continue reading Megan L. Brackney (Procedurally Taxing): The IRS’s Aggressive Enforcement Of Foreign Information Return Penalties Has Created Ethical Dilemmas For Practitioners (Part 2) (December 8, 2022)

Megan L. Brackney (Procedurally Taxing): The IRS’s Aggressive Enforcement Of Foreign Information Return Penalties Has Created Ethical Dilemmas For Practitioners (Part 1) (December 7, 2022)

Megan L. Brackney, of Kostelanetz LLP,  has made available for download her article “The IRS’s Aggressive Enforcement Of Foreign Information Return Penalties Has Created Ethical Dilemmas For Practitioners (Part 1)”, published on the Procedurally Taxing blog. The abstract is as follows: The IRS’s practice of assessing penalties against taxpayers who voluntarily attempt to get into … Continue reading Megan L. Brackney (Procedurally Taxing): The IRS’s Aggressive Enforcement Of Foreign Information Return Penalties Has Created Ethical Dilemmas For Practitioners (Part 1) (December 7, 2022)

Nina Olson (Procedurally Taxing): The Facebook Pixel and Unauthorized Use and Disclosure of Tax Return and Tax Return (November 29, 2022)

Nina Olson, Executive Director of the Center for Taxpayer Rights, has made available for download her article “The Facebook Pixel and Unauthorized Use and Disclosure of Tax Return and Tax Return”, published on the Procedurally Taxing blog. The abstract is as follows: Last week The Markup, an online investigative journalism site, published a report about the presence of … Continue reading Nina Olson (Procedurally Taxing): The Facebook Pixel and Unauthorized Use and Disclosure of Tax Return and Tax Return (November 29, 2022)

James Edward Maule, MauledAgain (November 29, 2022): Filing a Fraudulent Tax Return Is Bad, Filing More Than 3,000 Is Outrageously Bad

James Edward Maule’s MauledAgain tax blog entry discusses conspiracy to file fraudulent tax returns using fake identities. His article, “Filing a Fraudulent Tax Return Is Bad, Filing More Than 3,000 Is Outrageously Bad” includes the following commentary: Though as I’ve shared not long ago, I don’t write about every tax return preparer who gets into trouble … Continue reading James Edward Maule, MauledAgain (November 29, 2022): Filing a Fraudulent Tax Return Is Bad, Filing More Than 3,000 Is Outrageously Bad

TaxProfBlog – Lesson From The Tax Court: Taxpayers Behaving Badly 2022 (December 12, 2022)

Bryan Camp has published an article on the TaxProf Blog, titled “Lesson From The Tax Court: Taxpayers Behaving Badly 2022,” which presents TaxProf Blog’s customary ‘shake my head’ (SMH) facts of the year.  As is now customary, my last new blog of the year is a list of some of the cases I read during … Continue reading TaxProfBlog – Lesson From The Tax Court: Taxpayers Behaving Badly 2022 (December 12, 2022)

Forbes: The TCJA Five Years Later: State Tax Issues (December 6, 2022)

Forbes has published an article, “The TCJA Five Years Later: State Tax Issues,” which transcribes a discussion regarding state responses to SALT cap deductions by the TCJA and the forecasted future of these TCJA provisions. The article begins as follows: In the first of a three-episode series, Steven Wlodychak, formerly with EY, discusses the creation … Continue reading Forbes: The TCJA Five Years Later: State Tax Issues (December 6, 2022)

Forbes: America’s Best Tax And Accounting Firms 2023 (December 5, 2022)

Forbes has published an article, “America’s Best Tax And Accounting Firms 2023,” which discusses a selected list of the leading tax and accounting firms in America, as well as their methodology for doing so, list provided. The article begins as follows:  In any normal year, an accounting or tax firm is a combination financial expert, … Continue reading Forbes: America’s Best Tax And Accounting Firms 2023 (December 5, 2022)

Procedurally Taxing: Tax Court Issues Another 17-0 Ruling Regarding The Jurisdictional Nature Of Filing A Tax Court Petition (November 29, 2022)

Keith Fogg has made available for download his article, “Tax Court Issues Another 17-0 Ruling Regarding The Jurisdictional nature of Filing A Tax Court Petition,” published on Procedurally Taxing blog. The article begins as follows: Today the Tax Court ruled in Hallmark v. Commissioner, 159 T.C. No. 6 (2022) that the time period for filing … Continue reading Procedurally Taxing: Tax Court Issues Another 17-0 Ruling Regarding The Jurisdictional Nature Of Filing A Tax Court Petition (November 29, 2022)

Susan C. Moore: Out of Time? APA Challenges to Old Tax Regulations and the Six-Year Default Limitations Period (August 16, 2022)

Susan C. Moore, of University of Texas at Austin- School of Law, has made available for download her article, “Out of Time? APA Challenges to Old Tax Regulations and the Six-Year Default Limitations Period,” published in SRRN. The abstract is as follows: The government has begun to raise the six-year limitations period under 28 U.S.C. … Continue reading Susan C. Moore: Out of Time? APA Challenges to Old Tax Regulations and the Six-Year Default Limitations Period (August 16, 2022)

IRS Issue Number: Tax Tip 2022-180: Filing season readiness for tax pros (November 23, 2022)

The IRS has published their Tax Tip 2022-180, Filing season readiness for tax pros. The article begins as follows: As tax professionals begin preparing for the upcoming filing season, reviewing their security measures should be at the top of their to-do list. The Taxes-Security-Together Checklist can help tax them identify the basic steps they should take to … Continue reading IRS Issue Number: Tax Tip 2022-180: Filing season readiness for tax pros (November 23, 2022)

Grant Thornton: Tax Hot Topics (November 22, 2022)

Grant Thornton has published an article, "Tax Hot Topics", which discusses the updated IRS draft Schedules K-2/K-3 instructions. The article begins as follows: In today's Grant Thornton Tax Hot Topics, the IRS releases guidance regarding Schedules K-2 and K-3 while also estimating that the "tax gap" is nearly half a billion dollars, and President Joe Biden nominates … Continue reading Grant Thornton: Tax Hot Topics (November 22, 2022)

Federal Tax Crimes: Tax Attorneys Indicted for Fraudulent Tax Shelter and Related Conduct (November 18, 2022)

Jack Townsend has made available for download his article, “Tax Attorneys Indicted for Fraudulent Tax Shelter and Related Conduct”, published on his Federal Tax Crimes blog. The abstract is as follows: DOJ announced indictments in a press release, here, titled as follows: Tax Attorneys and Insurance Agent Indicted for Promoting and Selling Fraudulent Tax Shelter. The indictment … Continue reading Federal Tax Crimes: Tax Attorneys Indicted for Fraudulent Tax Shelter and Related Conduct (November 18, 2022)

KPMG Report: Proposed foreign tax credit regulations (November 21, 2022)

KPMG has made available for download their article, “Proposed foreign tax credit regulations”, which discusses additional guidance relating to the foreign tax credit (FTC). The abstract is as follows: On November 18, 2022, the U.S. Treasury Department and IRS (collectively, “Treasury”) released proposed regulations [PDF 371 KB] (REG-112096-22) (“2022 Proposed Regulations”) that provide additional guidance relating to the … Continue reading KPMG Report: Proposed foreign tax credit regulations (November 21, 2022)