The IRS announced today that the agency has become aware of limited circumstances in which it may be appropriate to provide relief from double taxation resulting from application of the repatriation tax under section 965, as amended by the Tax Cuts and Jobs Act (TCJA).
Month: January 2020
The Internal Revenue Service and Department of the Treasury issued Revenue Procedure 2020-11 that establishes a safe harbor extending relief to additional taxpayers who took out federal or private student loans to finance attendance at a nonprofit or for-profit school.
Congress recently enacted legislation that formally requires the IRS to maintain its Office of Appeals.
A Tax Court rejected a constitutional challenge to the law barring expense deductions for legal marijuana businesses. However, two judges embraced the taxpayer’s claim that IRC §280E could violate the 8th Amendment’s prohibition against excessive fines.
The IRS is increasing enforcement actions for syndicated conservation easement transactions including more coordinated examinations across IRS divisions and more criminal investigations. The goals of these audits may uncover billions of dollars of potentially inflated charitable contribution deductions for qualified conservation easements made through partnerships and limited liability companies (LLCs).