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You are here: Home / Archives for Tax Controversy

IRS Provides Wide-Reaching Extensions for Tax Filings and Payments, as well as Other Time-Sensitive Actions, Including Section 1031 Identification and Replacement Deadlines

April 14, 2020 by Cristin Keane

April 9, 2020: The Treasury Department and the Internal Revenue Service issued Notice 2020-23, which amplified Notice 2020-18 and Notice 2020-20 and modified Rev. Proc. 2014-42 with respect to calendar year 2020, and provided additional relief, postponing certain time-sensitive actions. Generally, Notice 2020-23 provides that any person who has a federal tax return or other form filing obligation specified in the Notice that is due to be performed (originally or pursuant ... Keep Reading »

Filed Under: Federal Income Tax, International Tax, LLCs and Partnerships, Qualified Opportunity Zone, Tax Controversy, Tax Exempt Organizations

Cost-Sharing Regulations Revived By Ninth Circuit

July 31, 2018 by Larry Kemm

The Ninth Circuit Court of Appeals reversed the Tax Court in Altera Corp. in the latest chapter of the dispute over the validity of cost-sharing regulations. The decision, issued on July 24, revives certain regulatory provisions previously invalidated by the Tax Court. (See Altera Corp. v. Commissioner, Dkt. Nos. 16-70597 & 16-70497 (9th Cir. 2018) rev’g 145 T.C. 91 (2015)). These regulations govern the allocation of stock-based compensation costs to a foreign ... Keep Reading »

Filed Under: International Tax, Tax Controversy

The Hidden Cost of Settling a Qui Tam Claim

June 20, 2018 by Adam Schwartz, Jordan August and Cristin Keane

Historically, taxpayers who made settlement payments to the government or relator under False Claims Act actions could offset those often considerable costs by deducting all or part of the payment for federal income tax purposes. But the Tax Cuts and Jobs Act, enacted in December, dramatically shifted the tax treatment of such payments, resulting in the potential loss of valuable tax benefits. Now more than ever, companies must carefully consider the tax treatment of ... Keep Reading »

Filed Under: Federal Income Tax, Tax Controversy

Tax Reform: Insurance Company Provisions

April 13, 2018 by Larry Kemm

Recent tax legislation, informally known as the Tax Cuts and Jobs Act (the “Act”) contains several changes that affect the insurance industry. A centerpiece of the Act lowers the corporate income tax rate to 21 percent, which generally applies to all corporations. Other reforms not specific to the insurance industry will also significantly affect many insurance companies. These include eliminating the corporate alternative minimum tax, a reduction of the general ... Keep Reading »

Filed Under: Federal Income Tax, Tax Controversy

Virtual Currency Tax Consequences

February 22, 2018 by Menasche Nass

A growing number of startups are offering virtual currencies to investors through initial coin offerings (ICOs) as a way to raise capital, often with little or no awareness of the tax consequences of their actions. Many startups sell specially created cryptocurrencies to initial project backers who expect the currency to increase in value if the startup succeeds. These cryptocurrencies, or tokens, are initially issued in fixed, limited amounts which generally can be used ... Keep Reading »

Filed Under: Federal Income Tax, Tax Controversy

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