The scope of the exception for taxpayers engaged in a real estate trade or business from the harsh consequences of Internal Revenue Code (IRC) section…
In Brief One of the most discussed changes in the Tax Cuts and Jobs Act of 2017 is the pass-through entity deduction created by the…
Demystifying IRC Section 965 Math
An Overview of the Taxation of Foreign Earnings
In Brief The Tax Cuts and Jobs Act introduced many changes to the tax code, with little time for taxpayers or professionals to prepare for…
Unexpected Inequities in an Environment of Declining Tax Rates
Considerations in Using the IRC Section 1341 Credit
In Brief Declining tax rates—such as those ushered in by the Tax Cuts and Jobs Act—can come with hidden consequences. Taxpayers who are required to…
Written Supervisory Approval of IRS Penalties
When Must It Be Given, and Who May Give It?
The Internal Revenue Code (IRC) imposes penalties on understatements of tax as a way to encourage voluntary compliance and deter noncompliant behavior. Generally, the revenue…
TPP | Reasonable Cause for International Information Return Penalties
What Is the Standard?
The Internal Revenue Code (IRC) requires the filing of a number of different information returns with respect to foreign entities or transactions. These “international information…
The “trust fund recovery penalty” can impose sizeable liabilities on officers and other employees of financially struggling or failed companies that fail to pay withholding…