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9100-3 to a foreign entity that missed the deadline to file Form 8832, allowing it to elect partnership classification effective Date 2. 7701-3 to be classified as a partnership for federal tax purposes.
S. and foreign-source income, particularly for income subject to Section 951A (GILTI) and deduction eligible income (DEI) under Section 250.
The United States Tax Court has delivered a landmark ruling in Sitaraman Jagannath v. C. Memo. 2026-92 (Sept. 50 in additions to tax for failing to file required forms.
S. Tax Court just handed down a stark reminder to taxpayers: forgetting to report IRA distributions can cost you $80,292 in back taxes, penalties, and interest. In Pal v. C. Memo.
The stakes in Swain v. 98 in unpaid federal income taxes for tax years 2017–2019, a balance that ballooned with penalties and interest after the Swains filed late returns. S.
The Tax Court’s September 24, 2026, decision in Valarie Lindsey v. C. Memo. 2026-94) delivered a stark reminder to taxpayers: the 90-day window to challenge an IRS deficiency notice is not a suggestion.
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The IRS's strategy to combat tax shelters is facing a pincer movement. While Mann and Green Valley forced the agency to use formal regulations, the Ryan challenge now threatens to invalidate those very regulations as arbitrary and capricious.
Four recent federal court cases—Mukhi, Silver Moss, Riddle Aggregates, and Schwarzbaum—refine the boundaries of tax penalties, balancing IRS authority against constitutional protections and statutory limits in areas like international reporting, conservation easements, and foreign bank accounts.
The Trump Administration's 2025 cryptocurrency tax framework represents a comprehensive approach to promoting innovation while reducing regulatory barriers, prioritizing individual freedom and self-custody by removing rules that make cold storage and direct ownership of digital assets difficult.
2026 will likely see dramatic re-adjustments to the balance of federal authority with serious implications for the IRS
In a landmark reversal, the Eighth Circuit ruled that the IRS cannot tax income that a taxpayer is legally prohibited from receiving, delivering a major blow to the agency's reallocation authority under Section 482.
An in-depth examination of criminal tax cases involving cryptocurrency and digital assets, including prosecution arguments, defense strategies, and unique case facts. This resource aggregates all known criminal tax prosecutions related to cryptocurrency.
We welcome submissions from tax attorneys for featured articles, case analyses, and commentary on US Tax Court decisions and tax jurisprudence.
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The Tax Court Blog provides in-depth US tax court analysis, expert commentary on IRS court cases, and insights for tax professionals and taxpayers.
Understanding the critical distinction between grantor and non-grantor trusts, their tax consequences, and the factual elements that determine classification. This guide explores the tradeoffs between tax treatment and asset protection.
Understanding Intentionally Defective Grantor Trusts (IDGTs), their purpose in estate planning, and how they are structured to achieve both estate tax exclusion and income tax advantages while maintaining asset protection benefits.
Understanding the critical tradeoffs between probate avoidance, estate tax minimization, and basis step-up benefits in trust and estate planning. This guide explores how different strategies balance these competing objectives.
Exploring the emerging intersection of blockchain technology, smart contracts, and trust law. This guide examines how wallet addresses can serve as trust identities, hardware security modules (HSMs) as trustees and beneficiaries, and the tax treatment and asset protection possibilities in the digital asset era.
Tax credit and exclusion for qualified adoption expenses
Tax treatment of alimony payments and separate maintenance payments
Deductions for ordinary and necessary business expenses under Section 162
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