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IRS Going All in on Use of ArtificiaI Intelligence
The IRS issued a news release today announcing a continued and more focused use of Artificial Intelligence (AI) to audit partnerships, large corporations and alleged tax shelter promoters. The news release follows Commissioner Werfel’s recent comments that “complex structures and tax issues present in large partnerships require a focused approach…
Continue Reading IRS Going All in on Use of ArtificiaI IntelligenceIt is a truism that agencies required to publicly release documents sometimes hold off on…
Continue Reading IRS is coming for NIL collectivesCalifornia FTB Unveils Microcaptive and Conservation Easement Settlement Initiative
The California FTB recently released a settlement initiative for taxpayers involved in microcaptive or syndicated…
Continue Reading California FTB Unveils Microcaptive and Conservation Easement Settlement InitiativeWednesday, September 27, 2023 | Philadelphia
Join leading practitioners from throughout the U.S. for an…
Continue Reading Save the Date for Fox Rothschild’s 2023 White Collar SymposiumThe Latest
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…
Continue Reading Tax Court Rules IRS Cannot Assess Certain International Reporting PenaltiesAs 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…
Continue Reading Increase in IRS Funding Leading to More Audits of Public CharitiesThe 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”…
Continue Reading U.S. Supreme Court Rules Against Government in FBAR Penalty CaseBy 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…
Continue Reading IRS Cracks Down on Charitable Contributions of CryptocurrencyOmnibus Bill Limits Conservation Easements, but the Long-Requested Safe-Harbor Does Not Apply to Current Cases
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…
Continue Reading Omnibus Bill Limits Conservation Easements, but the Long-Requested Safe-Harbor Does Not Apply to Current CasesIn 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…
Continue Reading Fox Rothschild Tax Litigation Team Topples IRS Conservation Easement RuleThe 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…
Continue Reading An Appealing Conversation: Insights From a Former Court of Appeals JudgeInspector General Faults Internal Revenue Service for Handling of Pandemic Relief Benefits
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…
Continue Reading Inspector General Faults Internal Revenue Service for Handling of Pandemic Relief BenefitsONLY 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…
Continue Reading Fox Rothschild’s Inaugural White-Collar Symposium, Thursday, November 3