In this article, Guillot analyzes whether a pending collection due‑process proceeding becomes moot when the underlying tax liability is satisfied through involuntary payments, as in Zuch, or through voluntary up‑front payments by the taxpayer to avoid the accrual of interest. Click here to read full article
In the News
PEOS MUST PROCEED WITH CAUTION WITH EMPLOYEE RETENTION CREDIT
As a result of the COVID-19 pandemic, Congress enacted the Employee Retention Credit (ERC), to help taxpayer businesses weather the storm. But despite the genuine benefit that ERC provides to qualifying businesses, the IRS has been faced with many fraudulent and questionable claims. Read more >
IRS Should Revise Overbroad Microcaptive Regs
On Jan. 14, final IRS regulations governing microcaptive insurance arrangements became effective, with several categories of microcaptives classified as abusive tax avoidance schemes and other transactions of interest…. Read more >
Rulings Show Local Laws Can Govern Contracts for R&D Tax Credits
A pair of taxpayer legal victories related to the research and development tax credit show how the US Tax Court approaches contract reviews when funding is a potential bar for federal tax credits. Smith v. Commissioner and System Technologies v. Commissioner are the first cases to consider the local, governing law when conducting a funding analysis related to…
