Connelly v Internal Revenue Service is a landmark SCOTUS decision that will impact business owners, partners, shareholders, members, and professional practitioners from a business perspective, succession planning, as well as from a personal estate planning point of view. The core issue of the case focused on the corporate contractual requirement...
How Did Moore v. United States Change U.S. Tax Law?
We have been waiting several months for the Supreme Court of the United States (SCOTUS) to render a decision in Moore v. United States. Initially, our questions focused on the issue of “realized or unrealized income” and whether income could be taxed before it is “realized.” The Court avoided this...
What is the “Abusive Use of Partnerships” and Why does the IRS Care?
What is now considered as the “abusive use of partnerships,” and why would this matter to the IRS? The agency recently released IR-2024-166, which is intended to provide “new guidance to stop partnerships from using sophisticated tax-free transactions that lack economic substance” to avoid paying taxes. . The IRS continues to...
The Risks of an IRS Quiet Disclosure
What are the risks of an IRS quiet disclosure? Is there a formal IRS processknown as a "quiet disclosure," and does the IRS honor this strategyfor amended tax returns? There is reason to be concerned about the growing number of clients withgenuine issues with unreported income (especially when it involves...
IRS Recommends Planning to Protect Important Documents in the Event of a Natural Disaster
In a recent notice the IRS is reminding all of us to undertake planning to protect important documents in the event of a natural disaster. This is National Wildfire Awareness Month, and we are in the midst of National Hurricane Preparedness Week (May 5 to 11). It is important to...
Quick Reminder to All Self-Employed Workers, Businesses and Estimated Tax Filers: Deadline Approaching
Just a quick reminder to all self-employed workers, businesses, and estimated tax filers: We are a week away from the Aprile 15 deadline for 2024 Q1 estimated tax payments. This includes many corporations, retirees, high income wage earners and expatriates who are required to “pay-as-you-go.” US taxpayers are required to...
What is the IRS Offshore Voluntary Disclosure Program?
What is the IRS Offshore Voluntary Disclosure Program and who is it designed to help? What are the guidelines for voluntary disclosure to the IRS and who is eligible to apply? The IRS Offshore Voluntary Disclosure Program is designed for US taxpayers who have not made a full disclosure of...
IRS Tax Refunds are Lower for Tax Year 2023 Thus Far
Did you know IRS tax refunds are lower for tax year 2023 thus far when compared to the same point a year ago? While the IRS just began accepting tax returns for tax year 2023 on January 29 of this year, there is already one troubling statistic according to the...
IRS Provides 2023 Tax Return Preparation and Filing Tips
Are you searching for 2023 tax return preparation and filing tips? The window officially opened to submit 2023 tax returns to the IRS on January 29, 2024. The following day the IRS released IR-2024-38, “Things to remember when filing 2023 tax returns” including return preparation and filing tips to help...