US Supreme Court Will Favor Taxpayer Challenges to the IRS
The US Supreme Court’s recent reversal of the Chevron doctrine in the Loper Bright Enterprises v. Raimondo case has significant implications for disputed tax matters. Here are some of the key potential impacts: Overall, the reversal of the Chevron doctrine
Comments on Proposed Regulations on Transactions with Foreign Trusts and Reporting Large Foreign Gifts
I was a principal author on behalf of the American Bar Association in preparing 60+ pages of comments submitted to the Internal Revenue Service (IRS) on proposed regulations concerning foreign trust transactions and recipients of significant gifts from foreign individuals.
IRS Form 8621 Frequently Misunderstood
IRS Form 8621, “Information Return by a Shareholder of a Passive Foreign Investment Company or Qualified Electing Fund,” is a tax form for U.S. taxpayers holding shares in Passive Foreign Investment Companies (PFICs). PFICs include foreign corporations, meeting specific income
IRS Criminal Investigations: A Serious Threat With Warning Signs
Criminal investigations are the most potent (and severe) tool in the IRS’s enforcement toolkit. While they are used in only a small fraction of cases, their consequences are very serious, potentially leading to personal, social, and financial ruin, professional license