Julia Ushakova-Stein

Oct 18, 2023 | mondaq.com | Larissa Neuman |Julia Ushakova-Stein |Michael Knobler |Sean McElroy

In this installment of U.S. Tax Review, tax partners Larissa Neumann, Julia Ushakova-Stein, and Mike Knobler, with input from Sean McElroy on crypto matters, review IRS guidance on R&D capitalization rules and the corporate AMT. They also explain Treasury's proposed regs interpreting broker reporting rules for digital assets, and examine taxpayer comments on the new FTC notice, amount B, and Moore amicus briefs. Read the full commentary and analysis in Tax Notes.

Sep 6, 2023 | mondaq.com | Julia Ushakova-Stein |Michael Knobler |Larissa Neuman

The IRS won two summons cases, one in the U.S. Court of Appeals for the Ninth Circuit and the other in the U.S. District Court for the Northern District of California, but the summons approved by the district court was narrower than the IRS wanted. In Agrama, 1 the Ninth Circuit affirmed a district court denial of a request for an evidentiary hearing and enforced an IRS summons against Frank Agrama for certain records, including records related to his prosecution for tax crimes in Italy.