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Recently, the SEC published a proposed new regulation (the "Proposed Rule") to amend the definition of an "exchange" for purposes of the Securities Exchange Act.

After a break for the holidays, this is the third of an expected five-part series on fraudulent transfers. In my first blog, I laid out the basic statutory framework, as well as a described...

For Americans and other foreign residents, Mexico is a very attractive country to live and work, because of its weather, rich culture, delicious food, friendly locals, and cost of living.

Created by Congress in 1971 as a tax incentive for domestic exporters of U.S.-made goods, the domestic international sales corporation (DISC) remains a viable tool...

The Treasury Department has recently issued a notice of proposed rulemaking under the Bank Secrecy Act regarding the reporting of convertible virtual currency ("CVC") mixing.

On December 9, 2022, Treasury and the IRS released proposed regulations that are intended to stop certain U.S. shareholder tax planning under section 951(a)(2)(B).

The recent Tax Court case of Kohout v. Commissioner addresses several common evidentiary issues in the context of tax disputes. A summary, chart, or calculation to prove the...

The Racketeer Influenced and Corrupt Organizations Act was enacted in 1970.

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...

No one wants to pay federal taxes. And this truism applies more so with respect to federal tax penalties.

That phrase reminds me of a Dilbert cartoon from about a decade ago that depicted the "pointy-haired boss" confronting Alice, the engineer, about her exceeding the company's permitted email storage.

L.L.C., Inc. and Fun Holdings, LLC v. Hegar, No. 13-21-00011-CV (Tex. App.—Corpus Christi June 8, 2023)—The Texas Thirteenth Court of Appeals affirmed the district court's dismissal of a case...

In 1998, Congress sought to provide additional protections to taxpayers through passage of the Internal Revenue Service Restructuring and Reform Act (the "Act").

Aloha! It's summer doldrums round here at Texas Tax Roundup this month. Everybody in Texas tax world must be off on vacation in some tropical paradise somewhere...

FBAR penalty procedures under Title 31 are similar to federal tax penalty procedures under Title 26. Under both Title 31 and Title 26, the IRS must make a timely assessment of the penalty prior to initiating collection action.

The United States Virgin Islands ("USVI") is an unincorporated territory of the United States. But that doesn't mean that they're subject to exactly the same laws as in the United States...

Freeman Law's "The Tax Court in Brief" covers every substantive Tax Court opinion, providing a weekly brief of its decisions in clear, concise prose.