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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 taxpayer failed to file Forms 5471 reporting his interest in a foreign corporation. The IRS assessed a $50,000 penalty (which…
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…
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…
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…
Continue Reading IRS Cracks Down on Charitable Contributions of CryptocurrencyThe Latest
Omnibus 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 3The Federal Government’s Continued Focus on COVID-19 Aid Fraud Leads to New Charges, Convictions and Sentencings
By Marissa Koblitz Kingman and Matthew D. Lee
The Justice Department recently announced new charges, convictions and sentencings in its ongoing initiative to target pandemic-related fraud, emphasizing the government’s commitment…
Continue Reading The Federal Government’s Continued Focus on COVID-19 Aid Fraud Leads to New Charges, Convictions and SentencingsIntroducing the Fox Rothschild White-Collar Symposium.
Join us in Philadelphia on the afternoon of November 3rd to meet with like-minded leaders to discuss the nationwide issues impacting white-collar criminal defense…
Continue Reading Join Us for Fox Rothschild’s Inaugural White-Collar Symposium on November 3Internal Revenue Service Announces Sweeping Penalty Relief for 2019, 2020 Tax Returns
By Matthew D. Lee and Jonathan Wasser
The Internal Revenue Service plans to provide widespread penalty relief for the late filing of certain tax and information returns for the 2019…
Continue Reading Internal Revenue Service Announces Sweeping Penalty Relief for 2019, 2020 Tax ReturnsMatthew D. Lee authored the Bloomberg Tax article, “US Supreme Court to Settle Long-Disputed FBAR Penalty Issue.” View the full article.
Continue Reading US Supreme Court to Settle Long-Disputed FBAR Penalty Issue