Welcome to Our Blog
Articles to help individuals and businesses evaluate their options for dealing with tax issues.
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 […]
Two Easements Conserved But Not in Perpetuity
In February of 2020, the United States Tax Court issued a Memo, Railroad Holdings, LLC T.C. Memo. 2020-22 (U.S.T.C. Feb. 5, 2020), and an Order, Rock Creek Holdings, LLC, Tax Court Order, 2/10/2020. Both the Memo and the Order pertain to the conservation easement in dispute in the cases. In the first case, the Court […]
The Challenges for Art Donation (Part 3 of 3): Trouble with $0 Donations
When it comes to the charitable donation of art, the Internal Revenue Service (IRS) has increasingly adopted a predictable strategy, as outlined in part two of this series. Similar to cases involving conservation easements, the IRS can even take the position that donated art is worth $0. While this is the IRS’s most extreme position […]
The Challenges for Art Donation (Part 2 of 3): Economic Substance
As discussed in part one of this series on art donations, a taxpayer who wishes to receive a tax deduction for their charitable donation of a work of art should take several steps in anticipation of the Internal Revenue Service’s (IRS’s) refusal to allow the deduction. In recent years, especially, the IRS has undertaken a […]
The Challenges for Art Donation (Part 1 of 3): An Introduction
Among the many ways that Congress uses tax laws to influence taxpayers’ spending, encouraging donations to charitable causes is perhaps the least controversial. Section 170 of Title 26 of U.S. Code, for example, has outlined Internal Revenue Service (IRS) policy on charitable contributions and gifts for decades. For many taxpayers, such donations include small payments […]
Government Transparency: Commissioner of Revenue to be Bound by Tax Court Decisions
On April 2, 2024, Senate File (SF) 4742, as a companion to House File (HF) 4934, was subject to a hearing before the Minnesota House of Representatives. HF 4934, like SF 4725, would amend Minnesota Statutes 2022, sections 270C.07, subdivision 1 and 270.33, to ensure that the Commissioner of Revenue (Commissioner) is bound by Minnesota […]
Government Transparency: Commissioner of Revenue to be Bound by Court Decisions
On Thursday, March 21, 2024, the Minnesota Senate Tax Committee had a hearing regarding Chair Ann Rest’s bill, Senate File (SF) 4725, which amends Minnesota Statutes 2022, sections 270C.07, subdivision 1 and 270C.33 to ensure that the Commissioner of Revenue is bound by Minnesota Tax Court decisions in situations where the Commissioner opts not to […]
Employee Retention Credit Voluntary Disclosure Program Ends March 22, 2024
The Employee Retention Credit (ERC) is a refundable tax credit for certain eligible business and tax-exempt organizations that had employees and were affected during the COVID-19 pandemic. The ERC Voluntary Disclosure Program is meant to help employers pay back the money they received after incorrectly filing for ERC claims. Businesses who incorrectly claimed the ERC […]
Anticipating Tax Litigators…And the IRS (Part 2 of 2): Tax Strategy Tips
Since the COVID-19 pandemic, the Internal Revenue Service (IRS) has had a long backlog that, due in part to funding received in the Inflation Reduction Act of 2022, it only began to catch up on in mid-2023. In the meantime, the IRS’s backlogs and delays might have lulled taxpayers into a false sense of security. […]
Categories
- Accounting
- Appeals
- Audits
- Bankruptcy
- Ben Wagner
- Charitable Contributions
- Claim For Refund
- Collection Issues
- Collection Options
- Covid 19
- Debt Forgiveness
- Employment Taxes
- Family Court
- FBAR
- Federal District Court
- FOIA and GDPA
- Foreign Trust
- Income and Deductions
- Independent Contractors
- Innocent Spouse Relief
- Installment Agreements
- Interest Netting
- Internal Revenue Service
- Kathleen (Splett) Pfutzenreuter
- Levy
- Liens
- Marijuana & Tax
- Minnesota Department of Revenue
- Minnesota Tax Court
- Offer In Compromise
- Offshore Voluntary Disclosure Program
- Penalties
- Profit Motive
- Real Estate
- Recovering Legal Fees
- Residency
- Sales & Use Tax Audits
- Settlements and Verdicts
- Summons
- Tom Regan
- Trust Fund Recovery Penalty
- U.S. Court of Federal Claims
- U.S. Tax Court
- Uncategorized
- Virtual Currency
- Voluntary Disclosure
- Wayfair
Recent Posts
- Treasury and Internal Revenue Service Crack Down on Related-Party Basis Shifting
- Internal Revenue Service Plans Dozens of Corporate Jet Audits
- Two Easements Conserved But Not in Perpetuity
- The Challenges for Art Donation (Part 3 of 3): Trouble with $0 Donations
- The Challenges for Art Donation (Part 2 of 3): Economic Substance