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 PracticeIan M. Comisky was featured in the Bloomberg Tax article, “Spotlight on Tax Controversy Partner Ian Comisky.” View the full article.
Continue Reading Spotlight on Fox Rothschild Tax Controversy Partner Ian Comisky
The Tax Court’s recent decision in Walquist v. Commissioner, 152 T.C. No. 3, further clarified the application of the supervisor approval requirement under section 6751(b)(1), which has been a
Continue Reading Tax Court Holds that Supervisor Approval Requirement Does Not Apply to Penalties Determined by Computer Program
I have written before about the battles being fought by cannabis businesses facing IRS examinations. IRS audits raise many issues for state legal cannabis businesses operating in violation of the
Continue Reading Tenth Circuit: No Fifth Amendment Defense to the Application of Section 280E
The IRS has been cracking down on conservation easement transactions for over ten years. Nevertheless, taxpayers have continued to claim charitable contribution deductions attributable to the donation of conservation easements
Continue Reading Conservation Easements: A Year End Review
Please join us for Fox Rothschild’s Second Annual Federal Tax Controversy Summit on December 12 in Philadelphia. We’ll be covering the latest developments in federal tax controversy and civil and
Continue Reading Only 2 Days Away – Fox Rothschild’s Second Annual Federal Tax Controversy Summit
Please join us for Fox Rothschild’s Second Annual Federal Tax Controversy Summit on December 12 in Philadelphia. We’ll be covering the latest developments in federal tax controversy and civil and
Continue Reading Fox Rothschild’s Second Annual Federal Tax Controversy Summit
In the latest Tax Court opinion addressing the application of Section 280E to cannabis businesses there is no good news. However, there is some new guidance. In Patients Mutual Assistance
Continue Reading Section 280E Litigation Update: Harsh Results for Resellers