This is the seventh in a series of ten client alerts summarizing the key provisions of the Taxpayer Assistance and Service Act (the “TAS Act”), a bipartisan legislative package introduced
Continue Reading Taxpayer Assistance and Service Act Title VII: WhistleblowersCivil Tax
Taxpayer Assistance and Service Act Title VI: IRS Independent Office of Appeals
This is the sixth in a series of ten client alerts summarizing the key provisions of the Taxpayer Assistance and Service Act (the “TAS Act”), a bipartisan legislative package introduced…
Continue Reading Taxpayer Assistance and Service Act Title VI: IRS Independent Office of AppealsTaxpayer Assistance and Service Act Title V: Tax Return Preparers
This article is the fifth in a series analyzing the proposed Taxpayer Assistance and Service Act (the “TAS Act”), bipartisan legislation introduced by Senators Crapo and Wyden to improve service…
Continue Reading Taxpayer Assistance and Service Act Title V: Tax Return PreparersThe Taxpayer Assistance and Service Act: Title III: Judicial Review
This article is the third in a series analyzing the proposed Taxpayer Assistance and Service Act (the “TAS Act”), bipartisan legislation introduced by Senators Crapo and Wyden to improve service…
Continue Reading The Taxpayer Assistance and Service Act: Title III: Judicial ReviewThe Taxpayer Assistance and Service Act: Title II: American Citizens Abroad
This article is the second in a series analyzing the proposed Taxpayer Assistance and Service Act (the “TAS Act”), bipartisan legislation introduced by Senators Crapo and Wyden to improve service…
Continue Reading The Taxpayer Assistance and Service Act: Title II: American Citizens AbroadThreat to Harvard’s Tax Status Reaches All Nonprofits – A Bloomberg Daily Tax Report Column
Fox Rothschild partners Brian Bernhardt and Adam Young authored an article in Bloomberg’s Daily Tax Report examining both the ancillary threats to all nonprofits as a result of the Administration’s…
Continue Reading Threat to Harvard’s Tax Status Reaches All Nonprofits – A Bloomberg Daily Tax Report ColumnFalse Claims Act Fallout from Pandemic Aid: What You Need to Know – A Fox Rothschild Webinar
Join Fox Rothschild White-Collar Criminal Defense & Regulatory Compliance partners Kevin Raphael, Brian Bernhardt, and Jonathan Wasser for a complimentary webinar addressing how to prepare for a potential Department of…
Continue Reading False Claims Act Fallout from Pandemic Aid: What You Need to Know – A Fox Rothschild WebinarIRS Provides Additional Extensions for Taxpayers Affected by Terrorist Attacks in Israel
IRS Notice 2024-72, provides relief for individuals and businesses affected by terrorism in Israel.
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FBAR: The Eleventh Circuit Holds That Willful FBAR Penalties are Subject to the Eighth Amendment Creating Circuit Split
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 Split
Should You File a Refund Lawsuit if the IRS Won’t Process Your ERC Claim?
As Employee Retention Tax Credit (ERC) claims pile up and the IRS shows no signs of lifting its moratorium on processing claims filed after September 14, 2023, businesses with unpaid…
Continue Reading Should You File a Refund Lawsuit if the IRS Won’t Process Your ERC Claim?