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Tax Impacts

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34 results

April 21, 2025

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7 min read

Tax Controversy and Litigation Series – Look to Cases from 2024

The year 2024 brought a breadth of noteworthy and significant tax decisions impacting both individual and corporate taxpayers. In the first of a recurring series, this article discusses tax cases from 2024 that we found intriguing and relevant to taxpayers.

...Read more

February 4, 2025

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4 min read

Micro-Captive Reportable Transactions Regulations Finalized; Challenged

On January 10, 2025, the Internal Revenue Service (IRS) and Treasury Department finalized regulations (REG-109309-22) that identify certain micro-captive insurance transactions, as well as transactions that are “the same as, or substantially similar to” those micro-captive transactions, as “listed transactions.”

...Read more

December 10, 2024

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12 min read

Prospective Tariffs on Goods from Mexico, Canada, and China

Since well before the November 6 election, President-elect Trump and his team have been discussing the imposition of tariffs on certain trade partners. The scope of possibilities range from all imports being subject to a 10% to 20% additional tariff, to the imposition of a 60% tariff on imports from China, to tariffs on vehicles from Mexico reaching as high as 100% to 200%.

...Read more

August 20, 2024

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4 min read

Second Employee Retention Credit Voluntary Disclosure Program Provides Relief for Some Employers

On August 15, 2024, the IRS announced a second Employee Retention Credit (ERC) Voluntary Disclosure Program available to certain employers who wish to self-report that they erroneously received credits for the 2021 tax year. 

...Read more

April 9, 2024

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3 min read

Taking Aim: IRS’s Compliance Campaign Makes Sports Industry Target of Enforcement Measures

November 6, 2023

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4 min read

Winston & Strawn Monthly Tax Controversy Update – October 2023

Welcome to the October 2023 edition of the Winston & Strawn Monthly Tax Controversy newsletter. In this installment, we highlight both tricks and treats from the spooky month of October concerning recent developments in the IRS’s priorities related to increased tax enforcement of corporations and the announcement of a withdrawal process for employee retention tax credit (ERC) claims.

...Read more

October 26, 2023

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4 min read

Lights, Camera, Audit: High-Income Taxpayers, Partnerships, Corporations, and Promoters Headline Recently Announced IRS Enforcement Priorities

The Inflation Reduction Act of 2022 (IRA), passed into law on August 16, 2022, represented a shift in the world of U.S. federal tax enforcement. This shift—or as most might suggest, a reversal of course—departed from the IRS that many have come to know in recent years, maligned by funding cuts, widespread attrition, and loss of institutional knowledge needed to administer the nation’s complex set of federal tax laws.

...Read more

October 2, 2023

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4 min read

IRS Backtracks on Penalties and Seeks to Settle Case Involving Backdated Documents

September 14, 2023

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6 min read

Tax Court Reproach of “Cut-and-Paste” Notice Another Blow to IRS Documentation Credibility

A Tax Court Memorandum Opinion expressing no confidence that a “slipshod-cut-and-paste” notice of deficiency was the version of the notice actually sent to the taxpayer is the latest in a string of rebukes from the Court and Congress questioning the IRS’s ability to retain credible and complete records.

...Read more

September 13, 2023

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4 min read

IRS Announces Increased Scrutiny of High-Income Taxpayers, Partnerships, Corporations, and Promoters

On September 8, 2023, the IRS announced that it will start a “sweeping, historic effort to restore fairness in tax compliance” by focusing its attention on high-income taxpayers, partnerships, large corporations, and promoters.

...Read more

September 5, 2023

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2 min read

Bangladesh and Hong Kong Sign Income Tax Agreement

On August 30, 2023, representatives of the governments of Bangladesh and the Hong Kong Special Administrative Region (SAR) signed a comprehensive avoidance of double taxation agreement (CDTA).

...Read more

August 31, 2023

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5 min read

Fallout from Backdated Documents Lands IRS in Hot Seat

Recent revelations involving documents found to be backdated by the IRS in the case of Lakepoint Land II, LLC v. Commissioner resulted in the Tax Court imposing sanctions on the IRS. Further inquiries ensued as to whether the IRS also proffered backdated penalty documents in other similar cases, hinting at a troubling picture of potentially systemic issues within the IRS.

...Read more

August 18, 2023

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1 min read

IRS Clarifies Federal Credit Unions May Claim Employee Retention Credit For 2021

In a memorandum released on August 18, 2023 (CCM 202333001), the IRS Office of Chief Counsel clarified the eligibility of federal credit unions to claim Employee Retention Credits under the Coronavirus Aid, Relief, and Economic Security Act (“CARES Act”) and the Internal Revenue Code.

...Read more

August 7, 2023

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4 min read

Winston & Strawn Tax Impacts Monthly Tax Controversy Update – July 2023

In this installment, we highlight two recent notable court cases, cover recent developments in Washington related to enforcement efforts related to the Employee Retention Credit (ERC), and highlight recent IRS guidance as to the taxation of staking rewards within the cryptocurrency space.

...Read more

July 31, 2023

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5 min read

IRS Cites Progress as House Committee Hearing Seeks Solutions to Employee Retention Tax Credit Woes

On Thursday, July 20, the House Committee on Ways and Means Chairman Jason Smith (R-MO-08) and Oversight Subcommittee Chairman David Schweikert (R-AZ-01) announced the Subcommittee’s hearing on “The Employee Retention Tax Credit Experience: Confusion, Delays, and Fraud” to be held the following Thursday. The announcement served to kick-off an unusually busy seven days of Employee Retention Tax Credit (ERTC) related activity in Washington and beyond. This included the publication of new guidance, public outreach, and the hearing itself.

...Read more

April 17, 2023

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7 min read

IRS’s Strategic Operating Plan Includes Objective Targeting High-Income Taxpayers and Large Corporations and Partnerships

The IRS outlined seven initiatives it seeks to accomplish in furtherance of its goal outlined within Objective Three.

...Read more

March 2, 2023

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2 min read

Non-Willful, Per-Form Penalties Suffer a Bittner Fate: Supreme Court Resolves FBAR Penalty Dispute

The Supreme Court has released its 5–4 decision in Bittner v. United States, No. 21-1195, holding that the Bank Secrecy Act’s penalty for non-willful failure to file a Report of Foreign Bank and Financial Accounts (FBAR) applies on a per-form basis—and not on a per-account basis, as argued by the government. 

...Read more

January 26, 2023

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4 min read

FTX Bankruptcy Tax Series: For FTX Customers Seeking Tax Losses, Details Matter

On November 11, 2022, FTX filed for Chapter 11 bankruptcy protection along with over 102 other FTX-affiliated entities. The company operated as a digital asset exchange, with several subsidiaries and affiliates, which included Alameda Research, a related cryptocurrency hedge fund. The bankruptcy of the entire operational enterprise and digital asset hedge fund has been a seismic event in the digital asset community, affecting over one million customers and eliciting attention from numerous governmental and banking organizations, including the Board of Governors of the Federal Reserve System (Federal Reserve), the Federal Deposit Insurance Corporation (FDIC), and the Office of the Comptroller of the Currency (OCC), which recently issued a joint statement calling attention to certain potential risks associated with digital assets and digital asset sector participants. Notably, the SEC and CFTC are also investigating FTX and analyzing acceptable regulatory framework for the industry.

...Read more

August 17, 2022

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2 min read

Biden Signs the Inflation Reduction Act of 2022 into Law

Today, President Biden signed into law the Inflation Reduction Act of 2022 (the “Act”). The Act ushers in, among other things, significant changes to the Internal Revenue Code and provides additional resources for the IRS.

...Read more

August 8, 2022

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3 min read

Senate Passes Inflation Reduction Act: Latest From the Hill

The Senate has passed the Inflation Reduction Act of 2022 (“Act”), sending the bill to the House, where lawmakers are expected to take up the bill later this week.

The Act’s passage follows a busy weekend on the Hill, which included lawmakers forging ahead with the comprehensive reconciliation bill with formal debate and the Senate voting Sunday 51 to 50 to pass the reconciliation bill, with Vice President Kamala Harris casting the tie-breaking vote.

...Read more
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About This Blog

Winston & Strawn’s Tax Impacts series features timely updates and insights impacting taxpayers, spanning from federal, international, and state and local tax planning to controversy.

Contributors

James N. Mastracchio

Partner

Susan Elizabeth Seabrook

Partner

Related Capabilities

  • Crisis Management
  • Tax
  • Tax Controversy & Criminal Tax

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