Yesterday 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 applicability of the economic substance doctrine to the Patel’s captive arrangement.
The Court invited amicus briefs on the issue and…
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…
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.
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…
Continue Reading IRS Makes Top Leadership Moves While Federal Government Remains ShutteredSubscribe to Tax Controversy & Financial Crimes Report
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IRS 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 LawsuitsThe head of the Justice Department’s Tax Division has departed for private practice, just as the planned dismantling of the Tax Division was set to take place. Karen Kelly, who…
Continue Reading DOJ Tax Division Leader Departs Amid Large-Scale ReorganizationIRS Leadership Turmoil Intensifies as Commissioner Billy Long Is Removed After Just Two Months
On August 8, President Donald Trump abruptly removed Billy Long from his position as Commissioner of Internal Revenue, making Long’s tenure the shortest for a Senate-confirmed commissioner in the tax…
Continue Reading IRS Leadership Turmoil Intensifies as Commissioner Billy Long Is Removed After Just Two MonthsPlease join us for our annual White Collar Symposium where our attorneys and guest speakers will unpack the most pressing issues in white-collar criminal defense, government investigations and regulatory compliance.…
Continue Reading Fox Rothschild’s Fourth Annual White Collar SymposiumIRS Leadership Turmoil Continues With Appointment of Yet Another Acting Chief Counsel While Chief of Appeals Announces Retirement
The Internal Revenue Service continues to experience significant leadership transition during a period of ongoing internal upheaval and uncertainty. The latest developments are the appointment of Kenneth Kies as the…
Continue Reading IRS Leadership Turmoil Continues With Appointment of Yet Another Acting Chief Counsel While Chief of Appeals Announces RetirementIRS Increased Audits Of High-Income Individuals During FY2024, But Future Of Initiative Under New Administration Is Doubtful
A recent report from the Treasury Inspector General for Tax Administration (TIGTA) found that the Internal Revenue Service increased audits of high-income taxpayers during fiscal year 2024, in line with…
Continue Reading IRS Increased Audits Of High-Income Individuals During FY2024, But Future Of Initiative Under New Administration Is DoubtfulOfficials at the U.S. Department of Justice have announced plans to eliminate its Tax Division and relocate its attorneys to other divisions within the department. In existence for more than…
Continue Reading Justice Department Plans to Eliminate Tax Division by End of SummerAbout 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.