The IRS’s ERC voluntary disclosure program has drawn concern from tax attorneys due to uncertainty around entering into the program and still being subjected to criminal prosecution. Extensive disclosure is…
By law, the IRS certifies taxpayers with “seriously delinquent” tax debts to the Department of State affecting passport status and renewal when certain conditions or thresholds are met. The IRS…
The Taxman, Technology Litigation and Cavalier Settlement Structures
Intellectual property (“IP”) is hugely important to businesses. Given that importance, IP owners must occasionally litigate against the unauthorized use of their technology. The costs of such litigation and appurtenant…
Many taxpayers have art collections. However, the art collections of some high-net-worth individuals, family offices, and business taxpayers may draw the unwanted eye of the IRS. With the increased focus…
We have previously spoken about monetized installment sales (“MISTs”) on Dollars & Sense. According to the IRS, these structures typically seek to defer gains associated with the sale of an…
For some time, the IRS has targeted fraudulent employee retention credit (“ERC”) claims. More recently, on December 21, 2023, the IRS issued guidance on a new voluntary disclosure program…
The Tax Court can be an unusually cruel place when it comes to deadlines. This is what a recent taxpayer found out in a Tax Court decision that denied their…
In recent years, U.S. taxpayers have engaged in “Malta pension plans,” utilizing these arrangements to contribute appreciated assets and claim tax exemptions under the U.S.-Malta tax treaty. Nevertheless, the U.S.
As the price of bitcoin rises, it is dominating the discussion regarding the future of cryptocurrencies, other digital assets and blockchain technology. Although the bitcoin price is a good thing…
FTX is embroiled in a $24 billion tax dispute with the Internal Revenue Service (IRS) in its bankruptcy case. The IRS claims FTX owes this amount in unpaid taxes, but…
The IRS recently issued a press release regarding its “continuous efforts to combat dubious Employee Retention Credit (ERC) claims” to announce an initial round of over 20,000 notification letters of…
In November 2023, Gray Reed Tax Partners Joshua Smeltzer and Matthew Roberts authored an article titled “Where Have All the Theft Losses Gone?” published in Taxes: The Tax Magazine.…
About the Gray Reed Tax Team
Gray Reed’s Tax Department provides experienced legal counsel to clients on all matters arising from international, federal, state and local tax laws. Our areas of expertise and services include ad valorem, asset protection, civil and criminal tax litigation, consulting, controversy, corporate, ERISA, estate planning, franchise, income tax, state tax, international, IRS audit, mergers and acquisitions, partnership, personal, planning, federal tax credits related to renewable energy and research and development expenses, property, real estate, reorganizations, and white-collar defense.