Insights

Is a Stiftung a Foreign Trust? Form 3520 Penalties?

Buff was Kind of Weak: FBAR Penalties

Tax Court in Brief | Deitch v. Comm’r; and Barry v. Comm’r | Deductible Interest Under IRC 163

Tax Court in Brief | Warner Enters., Inc. v. Comm’r | TEFRA and Partner’s Belated Objection to Penalty Determination

Changes to Corporate Capital in Equity Financing Transactions

Can Trustees Avoid Transfers Made Pursuant to Divorce Decrees or Other Agreements Incident to Divorce?

The 2022 Global Penalty Relief | Notice 2022-36 | Who qualifies and who does not? Relevant Implications for taxpayers with international assets/accounts

How Do I Know if I Have an IRS Form 3520/3520-A Filing Obligation?

Moments in Tax History | The Child Labor Tax Case | What’s a Tax?

Plea to the Jurisdiction

Tax Court in Brief | Medtronic, Inc. v. Comm’r | Section 482, Comparable Uncontrolled Transaction, Comparable Profits Method

Minnesota Nonprofit Corporations — Bread and Butter Regulatory Considerations

Information Technology Services and the Texas Sales and Use Tax

The Means Test

How are stock purchases treated for tax purposes under 26 USC 338? An IRS Letter Ruling on asset acquisitions.

Church Status: Can (and should) your religious nonprofit seek church status with the IRS?

Texas Tax Roundup — July 2022

Tax Court in Brief | Whistleblower 769-16W v. Comm’r | Can the Tax Court divest itself of jurisdiction over a whistleblower proceeding?