Recent taxpayer experiences suggest that IRS agents are becoming more aggressive in denying taxpayer claims of research and development tax credits through narrow construction of the so-called “substantially all” test of Code §...
Read MoreAt the beginning of, 2021, Congress slipped the so-called Corporate Transparency Act “CTA”), a new business reporting obligation, into the National Defense Authorization Act of 2021. Among other things, the CTA requires every...
Read MoreThe passage of the Tax Cuts and Jobs Act of 2017 (“TC&JA”) has increased the planning importance of so-called “unreimbursed partner expenses” for members of partnerships and LLCs treated as partnership. The Conference...
Read MoreBy: William E. Elwood The Internal Revenue Service has increased its scrutiny of inter-company pricing practices of taxpayers with foreign affiliates and has provided agents conducting audits with standard language requesting...
Read MoreBy: William E. Elwood The Internal Revenue Service has warned tax professionals, as the 2016 filing season begins, to be alert to a new email scam by cybercriminals posing as clients soliciting their services. The...
Read MoreBy William Elwood The IRS has signaled its intention to tighten the thumb screws a bit further on the reporting of foreign bank accounts, in recently published Announcement 2016-27. Under the so-called FATCA (Foreign Account Tax...
Read MoreBy William E. Elwood Congress’ parting Christmas present to the tax world was the extension of approximately 50 temporary tax provisions that had theretofore been routinely extended by Congress on only a one- or two-year basis....
Read MoreBy William E. ElwoodSeries LLCs, the “new kid” in the array of entities now available for business and transactional structuring, present new tax, creditor and opinion issues. The concept of “series” entities was conceived in...
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