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Wagner Tax Law Blog
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Federal Court Finds Transparency Act Unconstitutional: BOI Reporting Requirements Suspended
On December 3, 2024, the US District Court for the Eastern District of Texas found that the Corporate Transparency Act (CTA) was likely unconstitutional and issued a preliminary injunction to that effect. See Top Cop Shop, Inc. vs. Garland, No. 4:24-CV-478 (E.D. Texas 12/3/24). The CTA was enacted in 2021, and was meant to combat […]
Treasury and Internal Revenue Service Crack Down on Related-Party Basis Shifting
In June of 2024, the Internal Revenue Service (IRS) issued guidance attempting to address the perceived inappropriate use of existing partnership rules related to certain related-party basis-shifting transactions. These basis-shifting transactions are intended to generate tax benefits without any meaningful economic substance. IRS exam teams have reported repeated instances of inappropriate basis-shifting practices by related-party […]
Internal Revenue Service Plans Dozens of Corporate Jet Audits
On February 21, 2024, the Internal Revenue Service (IRS) announced that it plans to begin dozens of audits on business aircraft involving personal use, contributing to the Inflation Reduction Act’s efforts to improve tax compliance for high-income individuals and businesses. These audits will focus on aircraft usage by large corporations, partnerships, and wealthy taxpayers, and […]