The 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” basis, not a “per-account” basis, handing individuals an important victory.
Continue Reading U.S. Supreme Court Rules Against Government in FBAR Penalty Case
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 CryptocurrencyA former trial attorney for the IRS, Fox Rothschild Counsel Brian Bernhardt has a unique perspective to offer clients facing tax controversies and litigation. In a chat with Kristopher Flammang
Continue Reading Brian Bernhardt Featured on The Confident Retirement Podcast, Speaking about his Tax Controversy and Tax Litigation Practice