IRS Provides Additional Extensions for Taxpayers Affected by Terrorist Attacks in Israel
IRS Notice 2024-72, provides relief for individuals and businesses affected by terrorism in Israel.
Continue Reading IRS Provides Additional Extensions for Taxpayers Affected by Terrorist Attacks in IsraelFBAR: The Eleventh Circuit Holds That Willful FBAR Penalties are Subject to the Eighth Amendment Creating Circuit Split
Introduction
For years, FBAR litigants have made the commonsense argument that large willful FBAR penalties…
Continue Reading FBAR: The Eleventh Circuit Holds That Willful FBAR Penalties are Subject to the Eighth Amendment Creating Circuit SplitLast October, a District Court in Colorado turned the economic substance doctrine on its head.
Continue Reading Tax Court to Revisit Problematic Economic Substance RulingCue Up Your Summer Movie Watch List: Crypto Reporting Goes From Lampoon to Hero [1]
Summers are the ideal time for movies, baseball, long and winding road trips across the…
Continue Reading Cue Up Your Summer Movie Watch List: Crypto Reporting Goes From Lampoon to Hero [1]Subscribe to Tax Controversy & Financial Crimes Report
The Latest
The IRS has started its own Employee Retention Credit Olympics
Coinciding with the opening day of the Olympic games, the IRS issued IR-2024-198, again stating that it will deny tens of thousands of ERC claims that, according to the…
Continue Reading The IRS has started its own Employee Retention Credit OlympicsOn July 23, 2024, the U.S. Court of Appeals for the D.C. Circuit reversed the U.S. Tax Court in holding that inventory gain recognized by a nonresident alien individual partner…
Continue Reading Partnership Interest Sale Inventory Gain is Not U.S. Source IncomeLast April, in Farhy v. Commissioner, the Tax Court held that the IRS did not actually have authority to assess penalties under IRC § 6038. The result was devastating…
Continue Reading What’s Next for International Reporting Post-Farhy?As Employee Retention Tax Credit (ERC) claims pile up and the IRS shows no signs of lifting its moratorium on processing claims filed after September 14, 2023, businesses with unpaid…
Continue Reading Should You File a Refund Lawsuit if the IRS Won’t Process Your ERC Claim?The March 22 deadline for applying to the IRS Voluntary Disclosure Program (VDP) to repay improperly claimed Employee Retention Credits (ERC) at a discount is just around the corner. The…
Continue Reading March 22 ERC Voluntary Disclosure Deadline Rapidly ApproachingThe IRS is sending out over 125,000 collection letters to high-income taxpayers who did not file one or more federal income tax returns between 2017 and 2021. The IRS will…
Continue Reading IRS to Focus on High-Income Earners Who Have Not Filed Tax Returns Since 2017IRS Identifies Seven Employee Retention Credit Red Flags (and Other ERC Updates)
The IRS recently issued a news release identifying seven signs that a business’s Employee Retention Tax Credit (the “ERC”) may be incorrect. The IRS Commissioner also testified before the House…
Continue Reading IRS Identifies Seven Employee Retention Credit Red Flags (and Other ERC Updates)There are several new developments in the Internal Revenue Service’s ongoing campaign to combat false and fraudulent Employee Retention Credit (ERC) claims.
They include an indefinite extension of the agency’s…
Continue Reading IRS and Congress Expand Efforts to Address ERC FraudNew IRS Voluntary Disclosure Program Lets Businesses Repay Questionable Employee Retention Credits at a Discount
The IRS has announced a new Voluntary Disclosure Program (VDP) offering businesses a limited-time opportunity to repay improperly claimed Employee Retention Credits at a discount while avoiding penalties and interest.
Continue Reading New IRS Voluntary Disclosure Program Lets Businesses Repay Questionable Employee Retention Credits at a DiscountAbout this Blog
Published by attorneys in the White-Collar Criminal Defense & Regulatory Compliance and Taxation & Wealth Planning practices of national law firm Fox Rothschild LLP, Tax Controversy and Financial Crimes Report reports on the latest developments in all aspects of tax controversy and financial crimes.