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Wagner Tax Law Blog
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IRS Heeds Taxpayer Advocate’s Advice on Foreign Gift Tax Penalties
On October 24, 2024, Commissioner Daniel Werfel announced that the Internal Revenue Service (IRS) would end its practice of automatically assessing penalties for late-filed forms relating to foreign gifts or bequests, effective immediately. Contrary to popular belief, such penalties were frequently assessed against lower-income taxpayers, immigrants, and small businesses. The change in procedure, which relates […]
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 […]