Legal expenses for notice letters required as part of an application to the FDA for permission to produce and market generic drugs are capitalizable, but legal expenses for patent litigation as a result of certain certifications made during the approval process are deductible.
IRS Practice & Procedure
This article discusses issues taxpayers should consider during a litigation or arbitration process.
This item provides an overview of potential penalties and presents an argument as to why the Sec. 6656 failure-to-deposit penalty may not apply in some instances.
CARES Act provisions on net operating losses place new spotlight on the effect of filing superseding returns.
Various options are available for mitigating penalties for noncompliance with foreign return filing requirements.
In response to the coronavirus pandemic, the IRS issued guidance extending the temporary authorization to issue a number of IRS forms using electronic signatures through Dec. 31, 2021.
Increasingly limited IRS budgets and their effect on penalty and collections practices could be endangering the public fisc by creating incentives against voluntary compliance.
A bill recently proposed in Congress would authorize Treasury to regulate paid tax return preparers, and the AICPA strongly supports it.
The IRS warns of tax-related scams in a third of four installments.
In the second installment of this year’s “Dirty Dozen” list of tax scams, the IRS warns taxpayers to be vigilant for fraudulent schemes in the form of emails, text or social media messages, and phone calls.
Hijacking of economic impact payments and unemployment checks are spotlighted in the IRS’s annual alert, which warns taxpayers of the most prevalent scams and schemes the Service has identified.
A session at AICPA & CIMA ENGAGE 2021 shows how bedrock tax cases can help practitioners understand and resolve common issues that arise in practice.
New IRS final regulations clarify when a federally declared disaster will lead to mandatory 60-day postponement of certain tax-related deadlines.
Sec. 7345 does not violate the Fifth Amendment because it does not prohibit international travel.
To help taxpayers who might otherwise have been required to file amended income tax returns, the IRS announced that it will automatically issue to eligible taxpayers refunds of income tax paid on 2020 unemployment benefits.
The proposed $6 trillion fiscal year 2022 budget unveiled by the Biden Administration includes a host of tax items, including proposals to raise the corporate tax rate, raise the top tax rate for high-income individuals, limit like-kind exchanges, and make permanent recent temporary changes to various tax credits.
Reversing the Sixth Circuit, the Supreme Court held that an injunction sought against an IRS notice is not barred by the Anti-Injunction Act because it challenges a reporting requirement and not a tax.
In a letter to the IRS and Treasury, the AICPA recommended, in light of the ongoing COVID-19 pandemic, that the IRS implement fair, reasonable and practical penalty relief measures, including targeted relief from both the underpayment-of-estimated-tax penalty and the late-payment penalty for the 2020 tax year.
The Biden administration says the IRS should be given the authority to regulate paid tax return preparers who are currently unregulated, and the AICPA offers its recommendations in six key areas.
In response to a request for comments about planned revisions to Circular 230, the AICPA sent a letter making recommendations to the director of the IRS’s Office of Professional Responsibility.