Evan Walters

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Evan Walters focuses his practice on US and international taxation. He has experience across a wide range of issues involving corporate and partnership taxation. Read Evan Walter's full bio. 

Weekly IRS Roundup September 4 – September 8, 2023


By on Sep 14, 2023
Posted In IRS Guidance, Tax Reform, Tax Refunds

Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of September 4, 2023 – September 8, 2023. September 5, 2023: The IRS released Internal Revenue Bulletin 2023-36, which includes proposed regulations implementing the Mental Health Parity and Addiction Equity Act of 2008. September 5, 2023: The...

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Weekly IRS Roundup August 21 – September 1, 2023


By on Sep 5, 2023
Posted In IRS Guidance, Tax Reform, Tax Refunds

Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for August 21, 2023 – September 1, 2023.[1] August 21, 2023: The IRS released Tax Tip 2023-102, warning tax professionals to be prepared for a variety of schemes aimed at stealing sensitive information, including phishing and attacks on cloud-based applications....

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Weekly IRS Roundup August 14 – August 18, 2023


By on Aug 22, 2023
Posted In IRS Guidance, Tax Reform, Tax Refunds

Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of August 14, 2023 – August 18, 2023. August 14, 2023: The IRS published Internal Revenue Bulletin 2023-33, which includes: Revenue Procedure 2023-26, describing a program that provides an opportunity for fast-track processing of certain requests for...

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Weekly IRS Roundup August 7 – August 11, 2023


By on Aug 14, 2023
Posted In IRS Guidance, Tax Reform

Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of August 7, 2023 – August 11, 2023. August 7, 2023: The IRS published Internal Revenue Bulletin 2023-32, which includes: Notice 2023-53, setting forth updates on the corporate bond monthly yield curve and the corresponding spot segment...

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Weekly IRS Roundup July 31 – August 4, 2023


By on Aug 9, 2023
Posted In IRS Guidance, Tax Reform

Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of July 31, 2023 – August 4, 2023. July 31, 2023: The IRS released Revenue Ruling 2023-14, holding that a cash-method taxpayer who receives cryptocurrency units as validation rewards for staking cryptocurrency native to a proof-of-stake blockchain...

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Weekly IRS Roundup July 24 – July 28, 2023


By on Aug 1, 2023
Posted In IRS Appeals, IRS Guidance, Tax Reform, Tax Refunds

Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of July 24, 2023 – July 28, 2023. July 24, 2023: The IRS released Internal Revenue Bulletin 2023-30, which includes proposed regulations that specify the methodology for constructing the corporate bond yield curve used to calculate present...

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IRS Criminal Investigation Division Is on the Hunt for Malta Pension Plan Participants and Promoters


By , , and on Jul 25, 2023
Posted In Uncategorized

There has been a growing trend of US taxpayers contributing non-cash assets, such as appreciated property, securities and cryptocurrency, into Maltese pension plans since the US-Malta Tax Treaty went into effect in 2011. These transactions were marketed to many US taxpayers as a way to cash in on their earnings without being subject to US federal taxation....

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Weekly IRS Roundup July 17 – July 21, 2023


By on Jul 24, 2023
Posted In IRS Guidance, Tax Reform, Tax Refunds

Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of July 17, 2023 – July 21, 2023. July 17, 2023: The IRS released Internal Revenue Bulletin 2023-29, which includes Notices 2023-29, 2023-45 and 2023-47. These notices provide guidance to taxpayers seeking to qualify for the energy...

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Can the Government Sue for Tax Debts Outside Internal Revenue Code Procedures?


By , and on Jul 21, 2023
Posted In Appellate Courts, Court Procedure Matters, Trial Courts

On June 1, 2023, in United States v. Liberty Global, Inc., the US District Court for the District of Colorado held that the US Department of Justice (DOJ) can assert and seek judgment for federal income tax deficiencies using a common law right of action, bypassing the usual statutory tax deficiency procedures outlined in the Internal...

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With the IRS, Mail Delivery Counts!


By and on Jun 29, 2023
Posted In Appellate Courts, Court Procedure Matters, Tax Refunds, Trial Courts

Over the years, case law has developed around when a mail delivery method is acceptable to prove that a tax filing was made. The US Court of Appeals for the Fourth Circuit’s recent decision in Pond v. United States[1]  addresses how a taxpayer can prove delivery of a filing where the Internal Revenue Service (IRS)...

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