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The IRS Digital Asset Broker Reporting Requirements

The IRS digital asset broker reporting requirements were finalized earlier this year and impact all digital asset (i.e., cryptocurrency and Non-Fungible Tokens or NFTs) transactions beginning January 1, 2025.  What do investors in digital assets need to know?  How will these new regulations affect U.S. and international digital asset exchanges...

IRS Revisions to the Voluntary Disclosure Program for 2024

What are the IRS revisions to the Voluntary Disclosure Program for 2024?  The foundation of the current IRS Voluntary Disclosure Program (VDP) goes as far back as 2009 when the agency worked to provide U.S. taxpayers with a way to come into compliance with unreported or under-reported offshore income and...

The IRS Extension Deadline is in One Week

The IRS extension deadline is in one week, Tuesday, October 15, 2024. This is the last date for most U.S. taxpayers with extensions to file their 2023 federal income tax return without incurring late filing fees and other penalties. This year there are many exceptions. The weather has presented one...

Connelly v. Internal Revenue Service is a Game Changing Decision for every U.S. Privately Held Company

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...

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...