Introduction
For years, FBAR litigants have made the commonsense argument that large willful FBAR penalties, which can exceed the value of the unreported foreign accounts themselves, violate the excessive fines
Continue Reading FBAR: The Eleventh Circuit Holds That Willful FBAR Penalties are Subject to the Eighth Amendment Creating Circuit SplitSummers are the ideal time for movies, baseball, long and winding road trips across the U.S. in search of the perfect family vacation or, just as important, a reasonable crypto
Continue Reading Cue Up Your Summer Movie Watch List: Crypto Reporting Goes From Lampoon to Hero [1]Coinciding with the opening day of the Olympic games, the IRS issued IR-2024-198, again stating that it will deny tens of thousands of ERC claims that, according to the
Continue Reading The IRS has started its own Employee Retention Credit OlympicsOn July 23, 2024, the U.S. Court of Appeals for the D.C. Circuit reversed the U.S. Tax Court in holding that inventory gain recognized by a nonresident alien individual partner
Continue Reading Partnership Interest Sale Inventory Gain is Not U.S. Source Income
By 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 Cryptocurrency