Guaranteed payments vs. distributive share of income
Historically, the income tax treatment of a distributive share of partnership ordinary income did not differ significantly from that of...
Cryptoasset clarity needed for private fund managers
Sep 27, 2022
Current IRS guidance lacks direction for investing through a private fund The IRS’s guidance on cryptoasset income tax reporting standards...
Implications of legislative changes for R&E and software development costs
Sep 23, 2022
The 2017 law known as the Tax Cuts and Jobs Act (TCJA), P.L. 115-97, amended Sec. 174 to require capitalization and...
Tax Court: IRS counsel may reject administrative innocent-spouse approval
Sep 20, 2022
Although the IRS’s primary administrative unit for evaluating innocent-spouse requests concluded that a taxpayer was entitled to relief under Sec. 6015(c), the...
Passport revocation as a collection tool
Sep 16, 2022
The IRS has announced its intention to increase enforcement. Given the annual tax gap and anticipated federal budget increases, this...
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