On August 15, 2024, the IRS introduced a second voluntary disclosure agreement (VDA) program targeting companies that have claimed the employee retention credit (ERC) as provided by the CARES Act. Businesses that may have received
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
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
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
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,
Over the years, many people have come to our firm after being visited by the Criminal Investigation Division of the Internal Revenue Service (IRS-CI). In the event that agents from the Criminal Investigation Division of
The U.S. Supreme Court’s recent decision in Moore v. United States has definitively upheld the constitutionality of the repatriation tax, a one-time tax on accumulated foreign earnings of U.S. companies under the 2017 Tax Cuts
New Jersey motor vehicle owners can now simplify the transfer of their vehicle upon their death by designating a transfer on death (TOD) beneficiary. This new law change allows vehicles to bypass the often lengthy
To contest an IRS Criminal Investigation Division (CID) summons, you generally have a few options: While the most formal way to contest an IRS CID summons is through the court system, there might be a
The IRS Criminal Investigation Division (CID) frequently uses summonses to gather evidence in tax crime investigations. These summonses, authorized by law, grant special agents broad authority to examine tax returns, assess liabilities, and investigate any
Receiving a gift from a foreign person or entity can be a joyous occasion, but it also carries significant tax implications that necessitate meticulous attention. In the United States, Form 3520 plays a crucial role
The Internal Revenue Service’s (IRS) proposed regulations regarding Form 3520 and Code Section 6039F, as outlined in REG-108066-22, significantly change the reporting requirements for receiving foreign gifts. While the intent behind these regulations is laudable,
