Transactions involving the disposition of partnership property or partnership interests can trigger rules that limit business interest expense deductions. Section 163(j) of the Internal Revenue Code generally...
Interested in knowing what other partners are saying about how commercial lease agreements are evolving? Access exclusive market intelligence about private commercial lease agreements, as only told by...
The seller usually wants assurances that a buyer will be able to fund an acquisition at the closing, particularly if the closing is subject to a lengthy interim period between signing and closing. If a...
A company that receives a warning letter from the Food and Drug Administration (FDA) is on FDA's radar screen. In addition to responding appropriately to any actual or potential violations indicated...
We just added Arbitration Q&A content to Practical Guidance’s State Law Comparison Tool! Compare state laws on arbitration both pre-dispute and once a dispute arises across five key arbitration...
On January 12, 2022, the National Taxpayer Advocate (Advocate) released the 2021 Annual Report to Congress, stating that calendar year 2021 was "the most challenging year taxpayers and tax professionals have ever experienced." IR-2022-11. Notably, one category appearing for the first time on the Advocate’s “Most Litigated Issues” list is “whistleblower award determinations” under I.R.C. Section 7623(b)(1). The Advocate identified 12 opinions issued in the Tax Court where taxpayers challenged an IRS determination on issuing whistleblower awards between June 1, 2020, and May 31, 2021. In FY 2020, the Whistleblower Office made 169 awards to whistleblowers totaling more than $86 million, which included 30 awards under I.R.C. Section 7623(b). IRS Pub. 5241, Fiscal Year 2020 Annual Report IRS Whistleblower Office (Dec. 2020).
READ NOW »
Related Content
Practical Guidance Updates Featuring the latest updates from your Practical Guidance account.
Experience results today with practical guidance, legal research, and data-driven insights—all in one place.Experience Lexis+