On October 7, 2022, the Internal Revenue Service issued Notice 2022-53, which provides much-needed transition relief in the form of an IRS waiver of the 50% excise tax that could otherwise be imposed upon certain beneficiaries of qualified retirement plans (qualified plans) or individual retirement accounts (IRAs) who fail to take required minimum distributions (RMDs) during 2021 or 2022.

Historically and still today, the IRS requires that compensation paid to nonprofit executives be reasonable and not excessive. Up until now, tax-exempt organizations have not been subject to compensation limits on executive compensation; they have, however, been subject to the private inurement doctrine, intermediate sanctions, and excess benefit rules that impose an excise tax on nonprofit executives and managers who benefit from and knowingly participate in assigning compensation that exceeds the value of services performed. 

U.S. citizens and residents are subject to a number of IRS reporting requirements regarding assets held outside the U.S. Foreign situs assets and interests in offshore trusts significantly complicate tax reporting. Several such filing requirements are outlined below. 

In my prior role, I was involved in numerous examinations of financial products and transactions as a Large Business and International (LB&I) special trial attorney for the IRS. if you’re not on the inside at the IRS or have never had a client selected for an examination, you may not know its structure or procedures. But you should.

A better, stronger, faster Internal Revenue Service may soon be tracking down more wealthy tax cheats, thanks to the Inflation Reduction Act (IRA).