In the midst of Congressional consideration of the administration’s FY2026 budget request for the Internal Revenue Service (which was ultimately approved on February 3, 2026), a group of U.S. Senators is raising questions about fairness in tax enforcement. Ten Senators, nine Democrats and one Independent, are questioning whether recent workforce…
Continue Reading Group of U.S. Senators Sound Alarm About State of Federal Tax EnforcementGroup of U.S. Senators Question Sharp Drop in IRS Investigations of Abusive Tax Schemes
With a dire warning that “[t]ax shelter promoters are watching,” a group of U.S. Senators…
Continue Reading Group of U.S. Senators Question Sharp Drop in IRS Investigations of Abusive Tax SchemesThe four-day partial government shutdown – which did not impact the Internal Revenue Service –…
Continue Reading Partial Government Shutdown Ends With Funding Deal That Will Slash IRS BudgetIn the midst of the tax filing season, the Internal Revenue Service remains open for…
Continue Reading Federal Government Shutdown? Not at the IRSSubscribe to Tax Controversy & Financial Crimes Report
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As legislators face a January 30 government funding deadline, the House has passed legislation that would further erode the Internal Revenue Service’s annual budget and negatively impact federal tax enforcement. …
Continue Reading Congress Eyes Significant Cut to IRS BudgetAfter a few months of relative calm at the highest levels of the Internal Revenue Service (following turbulence and high-level executive turnover that marked much of 2025), the tax agency…
Continue Reading IRS Unveils More Leadership Changes as Tax Filing Season OpensYesterday the Tax Court issued its much awaited opinion in Patel v. Commissioner. After the Court disallowed deductions attributable to Patel’s captive insurance arrangement, it ordered briefing on the…
Continue Reading Tax Court Economic Substance Ruling is a Mixed Bag for TaxpayersOn October 15, 2025, the Wall Street Journal (WSJ) reported that the Trump administration plans to install administration-friendly officials in the IRS Criminal Investigative Division (IRS CI) to investigate left-leaning…
Continue Reading IRS Criminal Investigation Unit to Target Tax-Exempt Entities and Political DonorsAs everyone (hopefully) knows, the Government has been shut down for over two weeks now. Much has been written about the IRS having to furlough nearly half of its workforce…
Continue Reading The Government Shutdown Could Lead to Collections Nightmares for TaxpayersAs the federal government shutdown passes the two-week mark, and as thousands of Internal Revenue Service employees face furloughs and/or firings, the tax agency has announced a series of significant…
Continue Reading IRS Makes Top Leadership Moves While Federal Government Remains ShutteredIRS Has Funds to Continue Operations for Five Business Days After Potential Midnight Government Shutdown
Despite the apparent forthcoming government shutdown at midnight tonight, the IRS is prepared to briefly continue its operations according to its “lapsed appropriations” plan. The plan, released yesterday, September 29…
Continue Reading IRS Has Funds to Continue Operations for Five Business Days After Potential Midnight Government ShutdownIRS Provides Second Extension for Taxpayers Affected by Terrorist Attacks in Israel
In Notice 2025-53, the IRS provided relief for individuals and businesses affected by terrorism in the State of Israel throughout 2024 and 2025. The new notice extends the relief granted…
Continue Reading IRS Provides Second Extension for Taxpayers Affected by Terrorist Attacks in IsraelTexas Court Arms Taxpayers with a Powerful New Defense to FBAR Penalty Lawsuits
A district court in Texas has dismissed a lawsuit filed by the Justice Department to collect an FBAR penalty, concluding for the first time that the Internal Revenue Service’s administrative…
Continue Reading Texas Court Arms Taxpayers with a Powerful New Defense to FBAR Penalty LawsuitsAbout 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.