As a general matter, lawsuit recoveries are deemed fully taxable to the recipient …
Changes to Corporate Capital in Equity Financing Transactions, Part II.
In situations where corporations are needy for additional capital, existing and …
Country-by-Country Reporting: VIEs, PEs, Grantor Trusts and Other Nuances
As background, U.S. Treasury regulations require that the ultimate parent entity …
IRS Continues to Hunt for Cryptocurrency Investors with John Doe Summonses
UPDATE: On August 15, 2022, Judge Otis D. Write II in the Central District of California entered an order approving service of the summons by the IRS on sFOX for account and transaction records. The Department of Justice entered a
Government Motion in Kepke Case to Exclude Expert Testimony About the Law
Expert witnesses are not permitted to offer opinions consisting of their interpretation …
Tax Court in Brief – Eze v. Commissioner
Petitioner Nnabugwu C. Eze reported income and expenses from two sets of activities …
Collins Reminds that Corrective Actions Alone do not Always Negate Willful FBAR Penalties
he facts in Collins are not remarkable—indeed, they fit squarely within the facts …
Moments in Tax History | Eisner v. Macomber | Income, an Origin Story
In Eisner v. Macomber, the U.S. Supreme Court ruled that for purposes of the …
A Crypto Quagmire: Civil and Criminal Charges Filed against a Coinbase Manager for Insider Trading of Securities
Wahi leaked secret information to outside confidants regarding the prospective …
Filing an IRS Whistleblower Claim – Insight from Director Hinman
The IRS Whistleblower Office was established by the Tax Relief and Health …