IRS Announces Moratorium on the Employee Retention Credit and Provides Guidance for Civil Penalty Amnesty to Withdrawing Improper Claims, Also Known As - Don’t Deposit That Check and Hire Legal Counsel The expansion and strong marketing tactics of good-for-nothing “accounting advisors” who encouraged taxpayers to qualify for the Employee Retention Credit (“ERC”) when they did not technically qualify has caused…
(Note: This story was updated on June 26, 2023, with a correction.) IRS funding is back in the news. Less than a month after a debt ceiling agreement that would claw back some of the IRS funding previously authorized by the Inflation Reduction Act of 2022 (IRA), a bill is…
The tax treatment of legal settlements and judgments depends on the claims, whether the case settles or goes to judgment, how checks and IRS Forms 1099 are issued and more. The same tax rules apply to settlements and judgments, but you have more flexibility to reduce taxes when a case…
Every Friday night, my family celebrates cheese night. Okay, celebrate might be a strong word. But for the last few years, we've designated Fridays as cheese nights. At the end of a long week, it's nice to put out a spread of fruits and vegetables, olives and pickles, bread, and,…
As part of the Inflation Reduction Act (“IRA”) passed in August of 2022, $391 billion of governmental funding was allocated to energy and climate initiatives. The ability to transfer (i.e. sell) clean energy credits was part of the new legislation and covered under IRC Section 6418. The intent of IRC…
Falling into the Senior Accounting Officer regime for the first time The Senior Accounting Officer (SAO) regime forms a key part of any large UK business’s tax governance and risk management framework. While SAO is ultimately a compliance requirement - and penalties may be imposed on both SAOs and companies…
Some countries are considering making changes to their international tax laws on transfer pricing, and it may be wise for the United States to consider doing so as well. There is a pattern of countries enacting relatively vague transfer pricing legislation and then leaving it in place untouched for decades.…
A recent case demonstrates the impact that a stock-purchase agreement and life insurance can have (or not have) on the valuation of a closely held company for estate tax purposes. Before diving into the case, some context is helpful. It is not uncommon for closely held businesses to have buy-sell…
U.N. Secretary-General António Guterres is expected to release a much-anticipated report on international tax cooperation within a few weeks. As the international tax community waits — and speculates — on what that report might say, the secretary-general recently offered a small hint. At the end of May he released a…
Antawn Jamal Sanders has probably set a record although he is not likely pleased. How close can you get to having a Tax Court petition be timely, but still have it be late? Mr. Sanders missed by 11 seconds, maybe 9 seconds depending on how you look at it. Or…
The Supreme Court has added a new tax case to its docket for the 2023-24 term: Moore v. United States. As a result, the Court will consider whether a relatively new tax—the "mandatory repatriation tax"—created under a provision of the 2017 Tax Cuts and Jobs Act is unconstitutional under the…
In a declining economy, startups face an uphill battle when it comes to securing funding.…
With all of the recent news about artificial intelligence (AI), it got me thinking about…
A while back, I took a couple of my grandchildren on a tour of the…
Startups face numerous challenges on their journey to success, and failing to overcome any one…
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