Taxes

Although Tax Court Judge Cary Douglas Pugh rejected the IRS’s position on almost every key methodological detail in Facebook Inc. v. Commissioner, 164 T.C. No. 9 (2025), her opinion vindicated the general legitimacy of the method and the regulatory scheme that introduced it. Like most other major section 482 cases, especially those involving contributions to cost-sharing agreements (CSAs), Facebook was largely a clash between the parties’ economists. Both sides leaned heavily on valuation reports by expert witnesses to support their vastly differing valuations of Facebook’s platform contributions to a 2010 CSA with its Irish subsidiary, which included core technologies and…

Greetings from balmy Anchorage, Alaska! We’re in the middle of a warm spell–so much so that the world-famous Iditarod, which was scheduled to kick off here next week, has been moved to Fairbanks. It promises to be less temperate in the villages–the “real feel” at our first stop in my week of volunteer tax preparation in Alaska is forecast to be -1 degrees Fahrenheit. It’s been an incredible adventure so far. I didn’t, however, leave the news behind. Even as I was on my way (fun fact: it’s over 4,300 miles from Philadelphia to Alaska), there were several developments impacting…

Before moving from a state or establishing a second home, know how the state you currently reside in will react. States with net losses of residents are developing innovative and aggressive ways to capture tax revenue from their expatriates. The most recent innovation is the “exit tax” imposed on departing residents. A proposed wealth tax in California would tax residents and businesses with annual incomes exceeding $30 million ($15 million for married couples filing separately). They would have to pay a tax of 0.4% on their net worth exceeding the trigger amount and could be liable for the tax up…

IRS data from the third week of the tax filing season—the week ending February 14, 2025—continues to suggest that taxpayers are not excited about filing this tax season. Filing statistics are down in every category—from filing to processing to tax refunds. Early filing data reflects a continued downturn in tax returns received compared to the prior year. The dip is 4.9% compared to last year (and 10% down from the same filing period in 2023). The IRS still appears unmoved, claiming on its website that “[h]istorically, filing season numbers even out as more tax returns come in” and noting that…

Earlier this month, Elon Musk’s Department of Government Efficiency (DOGE) raised eyebrows when it requested access to sensitive taxpayer data at the IRS. According to various reports, DOGE is seeking access to the Integrated Data Retrieval System (IDRS). You can think of the IDRS as a master file, which includes tax returns and other taxpayer information, including bank records. Taxpayers and tax professionals alike have expressed concerns about the safety of their data. Some have even suggested that they will not file or pay their taxes until the matter is resolved. In addition to concerns about whether allowing access is…

The Trump Administration’s Department of Government Efficiency (DOGE) has pressed the IRS for permission to access individual tax return information of US households and businesses. While the DOGE team says it needs taxpayer data to search out “waste, fraud, and abuse,” such a move puts at risk deeply personal information on more than 150 million tax filers, with no clear benefit. DOGE staffers already accessed filers’ tax refund information through the database of the Treasury Department’s Bureau of Fiscal Service, the office that processes nearly all federal government payments. For example, that database includes the bank account information of every…

Many people confuse filing their taxes with doing tax planning. These are two very different services; ignoring this fact can cause you to be forced to leave the IRS a huge tip. Each year, around April 15, millions of Americans are forced to file their taxes; there is literally a deadline and penalties for not filing in a timely manner. However, no such deadlines or direct penalties exist for not doing proactive tax planning. That being said, the costs of not at least exploring the tax strategies available to you can be devastating for your financial security. Is My Tax…

We are about to face a new crisis in Washington,—the federal government may shut down in mid-March because it isn’t legally authorized to spend beyond that date. Only prompt action by President Trump and Congress can prevent the shutdown. But the shutdown may happen because of battles between Trump and the Democrats over spending, and fights among the Republicans themselves. We Could Have A Government Shutdown In March First, the problem. Spending for the federal government in our current fiscal year is only legally authorized until March 14. Congress failed to pass regular annual spending appropriations and instead resorting to…

The IRS will cut thousands of workers on probationary status as part of ongoing efforts by the Trump administration to reduce costs. It’s unclear how the cuts could impact the tax filing season, which kicked off on January 27, 2025. The cuts follow on the heels of other reductions to IRS personnel and the IRS budget. Cuts According to an official email viewed by Forbes, some of those cuts will be made this week. At least 3,500 IRS employees in the Small Business/Self-Employed (SB/SE) division of the IRS are expected to lose their jobs. The SB/SE division, currently headed up…

A court ruling in the Eastern District of Texas has ruled that beneficial ownership information (BOI) reporting requirements under the Corporate Transparency Act (CTA) are back in effect. And, as the government promised, companies have been granted a little extra time to file. Court Ruling On February 5, 2025, the Department of Justice filed an appeal in Smith v. U.S., one of two CTA winding through the court system in Texas. In its appeal, the government sought to stay an earlier preliminary injunction that would prohibit FinCEN from enforcing the CTA. In Smith, Judge Jeremy D. Kernodle, initially found that…

The future of federal taxes and the IRS under President Trump is unclear for many reasons. The uncertainty affects both the current tax-return season and individual tax-planning decisions that look beyond this year. The Tax Cuts & Jobs Act (TCJA), a wide-ranging set of tax-law changes that took effect in 2018, is set to expire after 2025. While the tax cuts of the TCJA seem likely to be extended beyond 2025, the details are already mired in preliminary wrangling in Congress, making it hard to predict exactly what the extended tax law will look like. Meanwhile, the IRS is experiencing…