In a monumental opinion, the Tax Court recently held that the IRS lacks authority to assess penalties imposed by IRC § 6038(b)(1) or (2). In Fahry v. Commissioner, the…

As part of the Inflation Reduction Act, the IRS will receive a nearly $80 billion funding increase, including more than $45 billion for enforcement, over the next decade. Audit staff…

The U.S. Supreme Court has ruled that the $10,000 penalty for a nonwillful violation of the foreign bank account reporting rules in the Bank Secrecy act applies on a “per-form”…

By Adam R. Young and Brian Bernhardt

On January 13, 2023, the IRS issued Chief Counsel Memorandum 202302012 (the “CCM”) establishing new rules for donations of cryptocurrency.  In the CCM…

On the morning of Dec. 20, 2022, we finally got a look at the language being negotiated in the 4,155 page Omnibus spending bill. Buried in the bill is new…

In a major victory before a 17-judge panel of the U.S. Tax Court, a Fox Rothschild litigation team led a successful challenge to an IRS rule and secured the reversal…

The Presumption of Innocence Podcast: Episode Sixteen

How can you ensure you’ve prepared your case for the best chance at success on appeal should the verdict not lean in your…

By Matthew D. Lee and Jonathan Wasser

Continued Internal Revenue Service processing delays are preventing businesses from receiving pandemic relief benefits, according to the U.S. Treasury Inspector General for Tax Administration…

ONLY TWO DAYS AWAY! It’s not too late to register for Fox Rothschild’s Inaugural White-Collar Symposium this Thursday in Philadelphia! Panels will address timely topics including Health Care Fraud, COVID-19…