Taxes

Introduction Taxpayers, like all people, are risk averse for the most part; they want to avoid financial uncertainty to the greatest extent possible. This is difficult to accomplish when the Internal Revenue Service (“IRS”) regularly attacks certain issues, often concluding that taxpayers owe additional taxes, penalties, and interest for several years. It is also a
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Corporations report their total cash payments of income tax — federal, state, and foreign combined — but they don’t identify, nor does the IRS reveal, how much federal income tax they pay. We believe, however, that we can make reasonable estimates from information reported by publicly traded companies in their financial statements. The adjacent table
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Spurring economic growth in America’s declining cities and regions has been a hard-to-achieve public policy goal. There’s hope that the Biden administration’s new industrial policies might boost growth where other efforts have failed. But the jury is still out. Industrial policy—government support for specific industries and sectors of the economy—has long been viewed skeptically by
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There is nothing inherently wrong with forming and utilizing a charitable remainder annuity trust (“CRAT”) for tax-planning purposes; people do it all the time. Issues arise, though, when taxpayers claim positions generating benefits that arguably exceed those contemplated by Congress and the Internal Revenue Service (“IRS”). When this occurs, enforcement actions begin, and participating taxpayers
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They say that relationships are all about timing. Putting aside the accuracy of that cliché generally, timing is certainly a key for taxpayers facing challenges by the Internal Revenue Service (“IRS”). Why? The law ordinarily provides that the IRS only has three years from the time taxpayers file particular returns to identify them as problematic,
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