This post is authored by Nicholas Lyskin (foxrothschild.com), Kristy Caron (foxrothschild.com) and Brian C. Bernhardt (foxrothschild.com)
Most appraisers don’t go to prison, and those that do, don’t go for appraising. So it’s no wonder why much has been made of the one-year prison sentence recently handed down to…
Continue Reading One Appraiser Goes to Prison, Another Goes Home: What to Expect from the IRSFox Rothschild LLP Partner Matthew D. Lee authored an updated version of the Foreign Account…
Continue Reading Matthew D. Lee Authors 2024 Update to FATCA Answer BookAmid Fraud Investigations, IRS Offers Employers an Opportunity to Withdraw Inaccurate Employee Retention Credit Claims
The IRS recently announced that it will offer certain employers an opportunity to withdraw Employee…
Continue Reading Amid Fraud Investigations, IRS Offers Employers an Opportunity to Withdraw Inaccurate Employee Retention Credit ClaimsIn Notice 2023-71, the IRS provided tax relief for individuals affected by Hamas’ terroristic action…
Continue Reading IRS Provides Extensions for Taxpayers Impacted by Hamas Terrorism in IsraelSubscribe to Tax Controversy & Financial Crimes Report
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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…
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 releasing those documents until a Friday afternoon, in the hopes it will be overlooked. The…
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 conservation easement transactions. Taxpayers who enter into the settlement program will not be able to…
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 afternoon of lively discussion covering the latest developments in the field, presented by Fox Rothschild’s…
Continue Reading Save the Date for Fox Rothschild’s 2023 White Collar SymposiumIn 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 CasesAbout 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.