Freeman Law

04/12/2023

On today's Freeman Law Insights blog, Matthew Roberts discusses the Tax Court's recent decision in Farhy.

Read Matthew's full post at https://buff.ly/43u9qcc.

#5471

The recent Tax Court decision in Farhy demonstrates that clever and novel arguments can carry the day in complex tax litigation matters. The taxpayer stipulated that he: (1) had Form 5471 filing obligations for his 2003 through 2010 tax years; (2) participated in an illegal scheme to reduce the amou...

04/11/2023

On April 10, 2023, the IRS issued proposed regulations under section 6751(b). In his most recent Freeman Law Insights blog, Matthew Roberts discusses three significant timing rules outlined in the proposed regulations regarding when supervisory approval must be obtained under section 6751(b).

Read Matthew's post at https://buff.ly/3KMRphL.

The IRS issued proposed regulations to clarify the timing of when written managerial approval must be obtained for a penalty to be effective under section 6751(b).

04/10/2023

On today's Freeman Law Insights blog, TL Fahring discusses Texas' March tax highlights including flowback, welding, sales and use tax, and franchise tax.

Read TL's full post at https://buff.ly/3mqaFZ5.

Freeman Law's Texas Tax Roundup discusses Texas' March tax highlights including flowback, welding, sales and use, franchise tax, and more!

04/05/2023

On today's Freeman Law Insights blog, Micah Miller explains accredited investors and their importance to U.S. companies.

Read Micah's full post at https://buff.ly/3KBRB3t.

An accredited investor is a person to whom companies can sell securities in an offering that is not registered with the SEC.

03/20/2023

On today's Freeman Law Insights blog, Cory Halliburton discusses two Technical Guides that were recently published by the IRS Exempt Organizations and Government Entities Division.

Read Cory's full post at https://buff.ly/40DPxNF.

TG 3-3, a 59-page gem, provides guidance on the meaning of exempt purposes described in section 501(c)(3) of Title 26 of the Internal Revenue Code (“Code”).

03/16/2023

On today's Freeman Law Insights blog, TL Fahring discusses two taxes on alcoholic beverages that impact holders of certain permits under the Texas Alcoholic Beverage Code.

Read TL's full post at https://buff.ly/3LLkAmv.

The state of Texas imposes two taxes on alcoholic beverages that impact holders of certain permits under the Texas Alcoholic Beverage Code. These taxes are the mixed beverage gross receipts tax and the mixed beverage sales tax.

03/13/2023

On today’s Freeman Law Insights blog, Andrew Mirisis discusses a recent IRS private letter ruling regarding mid-year CFC distributions and section 961(b)(2) gain.

Read Andrew's full post at https://buff.ly/3mKna1s.

This article discusses a recent PLR where the IRS ruled that section 961 basis adjustments apply to mid-year distributions.

03/08/2023

Congratulations to our Managing Member, Jason B. Freeman, for being recognized in JD Supra's 2023 Readers' Choice Awards and being named the #1 author in the Tax category!

Learn more at https://buff.ly/3mBfcHY.

03/03/2023

On today's Freeman Law Insights blog, Matthew Roberts discusses a recent Tax Court memorandum opinion in Fairbank and emphasizes the importance of filing timely and complete foreign information returns with the IRS.

Read Matthew's full post at https://buff.ly/3mmVXBV.

The IRS disagreed, contending instead that because Mrs. Fairbank had reportable interests in a foreign trust and did not file appropriate information returns (Forms 3520 and 3520-A) that the general three-year statute of limitations period did not apply.

02/28/2023

On today's Freeman Law Insights blog, Cory Halliburton discusses the monumental U.S. Supreme Court opinion of Bostock v. Clayton County and the right to religious freedom under Title VII.

"Employers who believe they qualify for a religious organization exemption from Title VII's prohibition of religious discrimination should carefully consider application of the statutes, Bostock, and its progeny."

Read Cory's full post at https://buff.ly/3SyUAfj.

This Insights blog addresses the aftermath of Bostock v. Clayton County and the ongoing collision of the right to religious freedom enjoyed by religious organization employers and the civil liberties of individual employees codified in Title VII of the Civil Rights Act of 1964.

02/23/2023

On today's Freeman Law Insights blog, Matthew Roberts provides some guidance to taxpayers who may be looking for a tax attorney to help them with unreported foreign accounts.

Checking the attorney's state bar record, federal tax credentials, and federal court experience are some steps a taxpayer can take to make an informed decision on their representation.

Read Matthew's full post at https://buff.ly/3Zyr7of.

If you have unreported foreign accounts, you are not alone. The IRS offers various programs for these taxpayers to regain compliance and sometimes mitigate criminal exposure. These programs include, for example, the IRS Streamlined Filing Compliance Procedures or the IRS’s Voluntary Disclosure Pro...

02/21/2023

On today's Freeman Law Insights blog, Matthew Roberts discusses a recent Order from the Southern District of California highlighting that the United States must show various other requirements outside the willful context when imposing FBAR penalties.

Read Matthew's full post at https://buff.ly/3IjkOh6.

A tax treaty between the United States and Mexico could serve to abrogate the definition of a “United States person” under the FBAR-reporting rules.