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
Continue Reading Tax Court Rules IRS Cannot Assess Certain International Reporting Penalties
Increase in IRS Funding Leading to More Audits of Public Charities
As 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
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U.S. Supreme Court Rules Against Government in FBAR Penalty Case
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.
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IRS Cracks Down on Charitable Contributions of Cryptocurrency
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 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 CasesFox Rothschild Tax Litigation Team Topples IRS Conservation Easement Rule
In 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 RuleAn Appealing Conversation: Insights From a Former Court of Appeals Judge
The 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 JudgeFox Rothschild Defense Team Wins Full Acquittal in High-Profile Political Corruption Trial
After a monthlong criminal trial in U.S. District Court, Fox Rothschild Partner Patrick Egan secured a verdict that fully exonerated three-term Philadelphia City Councilmember Kenyatta Johnson and his wife, Dawn
Continue Reading Fox Rothschild Defense Team Wins Full Acquittal in High-Profile Political Corruption TrialInspector 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 BenefitsFox Rothschild’s Inaugural White-Collar Symposium, Thursday, November 3
ONLY 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
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