Last Friday, Treasury released proposed foreign tax credit regulations aiming to clarify the cost recovery requirement and royalty withholding ...
Schedules K-2 and K-3 draft instructions for tax year 2022
Pass-through entities and partners alike should understand the compliance changes associated with the IRS's recent release of updated draft ...
New credit amounts for the Production Tax Credit for 2022
IRS announces new tax credit amounts under section 45 of the Internal Revenue Code, for the calendar year 2022.
OECD issues final Crypto-Asset Reporting Framework – now what?
The OECD’s updated crypto-asset reporting framework and CRS amendments will streamline reporting and exchange of information on crypto-assets.
Treasury Priority Guidance Plan 2022-2023 – Exempt Organizations
The Treasury Department and the IRS released the 2022-2023 Priority Guidance Plan, which contains a number of items affecting exempt organizations.
IRS makes statements on CARES Act Employee Retention Tax Credit risks
On Oct. 19, 2022 the IRS issued a news release warning employers to be wary of third parties who have ramped up campaigns to try and get ...
IRS releases required minimum distribution (RMD) guidance
Notice 2022-53 announced the IRS’s intent to publish final regulations addressing required minimum distributions (RMDs) from certain plans.
New IRS draft forms reflect broader digital asset enforcement
The IRS changed “virtual currency” to “digital asset” in new draft forms, signaling enforcement efforts toward digital assets, including NFTs.
IRS provides simplified measures for correcting common S corporation missteps
IRS Rev. Proc. 2022-19 provides S corporations with simplified procedures to resolve common issues without a private letter ruling.
Distressed acquisitions & credit bidding debt: an M&A tax perspective
Tax considerations for buyers and sellers of distressed companies under section 363 of the Bankruptcy Code.
Treasury releases technical corrections to final FTC regulations
IRS releases a set of technical corrections (2022-15867 and 2022-15868) to calm taxpayer concerns regarding the final FTC regulations.
Eleventh Circuit reverses Tax Court’s penalty approval analysis.
The Eleventh Circuit overrules the Tax Court and holds supervisory approval any time before assessment satisfies section 6751(b).
IRS proposes guidelines to clarify access to Independent Office of Appeals.
Section 7803(e) provides taxpayers a general right to the IRS Independent Office of Appeals. IRS proposed regulations contain a list of 24 types ...
The new corporate minimum tax: overview and highlights
The Inflation Reduction Act of 2022 imposed a new 15% alternative minimum tax on large corporations. Notably, the tax is based on a ...
IRS issues guidance on transition rules for EV credits
IRS guidance helps taxpayers navigate the transition from existing rules for claiming EV credits to new rules enacted by the IRA including ways ...
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