Until relatively recently, the number of individuals who bought and sold cryptocurrencies (crypto) and other digital assets was fairly small. Over the last few years, however, that number has continued to grow exponentially. As a result, there has been an increasing number of calls for government regulation on how individuals’ and businesses’ actions on crypto [...]
On March 9, 2022, President Biden signed an executive order setting out his administration’s strategy regarding digital assets: Executive Order on Ensuring Responsible Development of Digital Assets (Executive Order). The Executive Order is broadly concerned with protecting investors and consumers, guarding against illicit activity, and ensuring financial stability, both in the U.S. and in global [...]
The Internal Revenue Service (IRS), like any self-respecting bureaucracy, sometimes makes mistakes. When those mistakes occurs, a taxpayer can make a “qualified offer,” which might lead to a settlement and obviate the need for a drawn out court battle. If the case nevertheless goes to Tax Court, and the taxpayer prevails in their case, they [...]
There has been a potentially landscape-altering decision out of the Fifth Circuit Court of Appeals (Court) regarding Reports of Foreign Bank and Financial Account (FBAR) penalties. In United States v. Bittner, that Court has held that each failure to report a qualifying account is a separate violation. This is a significant split from the Ninth [...]
Appearing in the October of 2021 issue of ALI CLE’s The Practical Lawyer is an article by Kathleen E. (Splett) Pfutzenreuter and Benjamin A. Wagner addressing a variety of tax topics that small and solo firm lawyers should be ready to answer. The tax topics covered include: when to talk to a tax accountant or [...]
The United States Department of Treasury (the Treasury) issued “The American Families Plan Tax Compliance Agenda,” detailing how the current administration intends to tackle the ever-looming noncompliance issue. This report was a follow up to the April of 2021 American Families Plan that included proposals that the administration announced to increase tax compliance. The Treasury [...]
Corporate income taxes are generally the responsibility of the corporation and not the individuals that own the corporation. However, there are circumstances where the Internal Revenue Service (IRS) can pursue an assessment of those obligations against the individuals. One of those methods of assessment is an alter ego and it is pursued when the IRS [...]
In January of 2018, the Internal Revenue Service (IRS) issued a press release advising delinquent taxpayers to negotiate reasonable alternatives to enforced collection action, or risk losing their passport. Please find more on that press release and the IRS’s initial approach to passport revocation here. Suffice to say, the initial process for passport revocation was [...]
The on-going COVID-19 pandemic has had a dramatic impact on the daily operations for the Internal Revenue Service (IRS). The IRS has appeared to have done its level best to provide taxpayers with options for securing vital documentation. Though, taxpayers attempting to obtain a lien release or certificate of discharge have experienced some delays in [...]
The proper classification of workers is a decision that is critical to the success or failure of many small businesses. This is especially true in light of the on-going public health crisis, where margins have been squeezed to their absolute limits. For more information relating to the classification of workers, please see these previous blog [...]