Tax alert

New IRS draft forms reflect broader digital asset enforcement

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 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

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

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.

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.

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 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 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 ...
New tax on publicly traded corporations that repurchase their stock

New tax on publicly traded corporations that repurchase their stock

The Inflation Reduction Act, passed by Congress, contains a new 1% tax on stock redemptions by certain corporations. In what situations does the ...
The Inflation Reduction Act of 2022 proposes $80 billion in additional funding for the IRS

The Inflation Reduction Act of 2022 proposes $80 billion in additional funding for the IRS

The Inflation Reduction Act of 2022 provides significant funding for the IRS over the next 10 years. The IRS is expected to use over half the ...
CHIPS Act of 2022: Tax incentives for semiconductor manufacturers

CHIPS Act of 2022: Tax incentives for semiconductor manufacturers

The CHIPS Act of 2022 funds grants and a new federal income tax credit to facilitate domestic manufacture of semiconductors.
Late filing penalties may apply when e-file mandate not met

Late filing penalties may apply when e-file mandate not met

IRS non-precedential guidance clarifies that penalties for late filing may apply to certain returns that are paper-filed if electronic filing ...
States begin to consider digital asset taxation as sessions end

States begin to consider digital asset taxation as sessions end

A number of states begin to consider or take steps related to the state taxation of digital assets as the economy for these assets continues to grow.
Contextualizing cyber risk: Mapping business as a system

Contextualizing cyber risk: Mapping business as a system

Boards need a better understanding of how business could be impacted by cyberthreats.
Executive Order provides path to regulation of digital assets

Executive Order provides path to regulation of digital assets

Executive Order provides an outline for next steps related to guidance and regulation in the digital asset space.

Top Professionals Ready To Serve You

The FMF&E team prides itself on ensuring that you have quick and easy access to top professionals for any challenge. Our unique model gives our clients confidence that our experienced team can be trusted with your most complex challenges.