The U.S. Tax Court held on April 3, 2023, in Farhy v. Commissioner, 160 T.C. No. 6 (April 3, 2023), that the Internal Revenue Code does not provide authority for the Internal Revenue Service to assess penalties imposed under IRC Sec. 6038(b)(1) or (2) for failure to file Form 5471, Information Return of U.S. Persons
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U.S. Tax Court Rules IRS Lacks Statutory Authority to Assess Penalties for Failure to File Form 5471
Accounting For Investments in Tax Credit Structures Using The Proportional Amortization Method
IRS Issues Notice of Proposed Rulemaking for Supervisory Approval of Penalties
On April 11, 2023, the U.S. Treasury Department and the IRS issued proposed regulations under IRC Section 6751(b) (REG-121709-19; 88 F.R. 21564-21572]. Section 6751(b) requires written supervisory approval of certain penalties prior to assessment and in recent years, courts have adopted different interpretations of various aspects of this requirement. The proposed regulations are intended to
Read MoreState and Local Income Tax Issues to Consider Before Making Your Next Tax Payment
State and local taxes represent a key and often material part of a business’s total tax liability. Many states are reporting budget surpluses, reducing tax rates and offering new credits and incentives, but states are also looking to expand taxation of the digital and internet economy. With the calendar year 2022 tax reporting and filing season
Read MoreSecure 2.0 Act of 2022 Introduces Key Changes for Workplace Retirement Plans
The Consolidated Appropriations Act, 2023 (Public Law No. 117-328) that was signed into law on December 29, 2022 by President Joe Biden includes the SECURE 2.0 Act of 2022, which introduces over 90 changes to the federal rules governing workplace retirement plans. This landmark legislation builds on the original SECURE Act that was enacted on
Read MoreTreasury, IRS Release Additional Information on Clean Vehicle Provisions of Inflation Reduction Act
Cost Optimization Strategies for Resilient Growth
Planning to deduct for losses this tax season? Be sure to read the fine print
6 Mistakes Manufacturers Make During Post-Merger Integration
Manufacturers leave value on the table by failing to properly integrate acquisitions. Although 2021 was a record year for M&A, many of those deals have not reached their full potential. According to the 2022 BDO Manufacturing CFO Outlook Survey, 31% of manufacturers say recent deals have failed to achieve expected synergies. Manufacturers who have
Read MoreClaiming an Exemption from Self-Employment Tax as a Limited Partner? Think Twice
Limited partners claiming an exemption from Self-Employment Contributions Act (SECA) taxes may be putting themselves at risk – in certain circumstances. In fact, more recently, it has become even riskier. Why? Because the rules are unclear, and the IRS has prioritized this issue in examinations and successfully challenged exemption claims in court. Unfortunately, neither the
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