On April 17th, the Fifth Circuit Court of Appeals held that an FCC penalty violates the Seventh Amendment based on the Supreme Court’s landmark ruling in SEC v.
Continue Reading Another Civil Penalty Falls under Jarkesy – What’s Next?Harvard University’s Tax-Exempt Status in Jeopardy: What It Could Mean for Your Organization
Nonprofit schools and other entities should be prepared to defend their tax-exempt status in the event of an IRS audit after President Trump called for revoking Harvard University’s tax-exempt status.
Continue Reading Harvard University’s Tax-Exempt Status in Jeopardy: What It Could Mean for Your Organization
IRS Turns to New ‘John Doe’ Summonses in Continuing Quest to Combat Offshore Tax Evasion
In recent months the Internal Revenue Service (IRS) has started issuing “John Doe” summonses to overseas trust companies and their related entities and vendors to identify clients and obtain their
Continue Reading IRS Turns to New ‘John Doe’ Summonses in Continuing Quest to Combat Offshore Tax EvasionEmployee Retention Credit Claim Resolution Has No End in Sight
Matthew D. Lee, Brian C. Bernhardt, and Jonathan M. Wasser co-authored the Bloomberg Tax article, “Employee Retention Credit Claim Resolution Has No End in Sight” on January 29, 2025. View
Continue Reading Employee Retention Credit Claim Resolution Has No End in SightIRS 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.
Continue Reading IRS Provides Additional Extensions for Taxpayers Affected by Terrorist Attacks in Israel
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 SplitTax Court to Revisit Problematic Economic Substance Ruling
Last October, a District Court in Colorado turned the economic substance doctrine on its head. In Liberty Global, Inc. v. US, a District Court granted the Government’s motion for
Continue Reading Tax Court to Revisit Problematic Economic Substance RulingCue Up Your Summer Movie Watch List: Crypto Reporting Goes From Lampoon to Hero [1]
Summers 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]The IRS has started its own Employee Retention Credit Olympics
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 OlympicsPartnership Interest Sale Inventory Gain is Not U.S. Source Income
On 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