Jeffrey Golds

Mar 20, 2024 | natlawreview.com | Jeffrey Golds |Christie R. Galinski |Raymond Lahoud |Frank Davis

On February 21, 2024, the IRS announced plans to increase funding under the Inflation Reduction Act to audit the use of corporate aircraft by large corporations, partnerships, and high-income individuals.

Mar 8, 2024 | jdsupra.com | Christie R. Galinski |Jeffrey Golds

As previously reported by Miller Canfield, unscrupulous promotors caused many taxpayers to file claims for the Employee Retention Credit even when they did not qualify. As a result, the IRS views claims for this credit with suspicion and has created several programs allowing taxpayers to withdraw their claims without penalty.

Feb 16, 2024 | jdsupra.com | Christie R. Galinski |Jeffrey Golds |Loren Opper

Altria Group, Inc. v. United States[1], a federal income tax case pending in federal district court in Virginia, shows the importance of laying groundwork for litigation long before a complaint is filed. At issue is a difficult question of statutory interpretation. The taxpayer (“Altria”) – or those in the same position – undoubtedly encouraged Congress to express its intent in legislative history.

Jan 19, 2024 | jdsupra.com | Christie R. Galinski |Jeffrey Golds |Loren Opper

In Private Letter Ruling 202352011 (December 30, 2023), the taxpayer asked the IRS to determine the amount that it will realize in a property transaction. The taxpayer will receive the property in an arm’s length exchange with its counterparty, but the taxpayer will not be able to reasonably ascertain the value of the property received.

Jan 5, 2024 | natlawreview.com | Stefanie Marrone |Richard Greenberg |Daniel Jacobs |Jeffrey Golds

As previously reported by Miller Canfield, in October 2023 the IRS launched a withdrawal program for Employee Retention Credit (ERC) claims for employers who now doubt the validity of their claim. Unfortunately, employers who already deposited their refund checks were not included in this program. To address this discrepancy, the IRS announced a new voluntary disclosure program on December 21, 2023, allowing for the penalty-free repayment of ERC credits.