In a June 9 opinion, the Tax Court held that a married couple were not engaged in horse breeding and training activities for profit and sustained the IRS’s disallowance
Continue Reading Horse Breeding and Training Expense Deductions? Tax Court Says NeighTaxpayer Assistance and Service Act Title IX: Small Business
This is the ninth in a series of ten client alerts summarizing the key provisions of the Taxpayer Assistance and Service Act, a bipartisan legislative package introduced on February 26
Continue Reading Taxpayer Assistance and Service Act Title IX: Small BusinessCourt Ruling Creates Refund Opportunity for Pandemic-Era IRS Interest and Penalties
Fox Rothschild attorneys Matthew D. Lee, Brian C. Bernhardt, and Jonathan M. Wasser have authored a client alert regarding a new refund opportunity for taxpayers who accrued IRS
Continue Reading Court Ruling Creates Refund Opportunity for Pandemic-Era IRS Interest and PenaltiesIRS 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 SplitIRS to Focus on High-Income Earners Who Have Not Filed Tax Returns Since 2017
The IRS is sending out over 125,000 collection letters to high-income taxpayers who did not file one or more federal income tax returns between 2017 and 2021. The IRS will
Continue Reading IRS to Focus on High-Income Earners Who Have Not Filed Tax Returns Since 2017IRS Identifies Seven Employee Retention Credit Red Flags (and Other ERC Updates)
The IRS recently issued a news release identifying seven signs that a business’s Employee Retention Tax Credit (the “ERC”) may be incorrect. The IRS Commissioner also testified before the House
Continue Reading IRS Identifies Seven Employee Retention Credit Red Flags (and Other ERC Updates)
IRS Going All in on Use of ArtificiaI Intelligence
The IRS issued a news release today announcing a continued and more focused use of Artificial Intelligence (AI) to audit partnerships, large corporations and alleged tax shelter promoters. The news
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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.
Continue Reading U.S. Supreme Court Rules Against Government in FBAR Penalty Case
Internal Revenue Service Announces Sweeping Penalty Relief for 2019, 2020 Tax Returns
By Matthew D. Lee and Jonathan Wasser
The Internal Revenue Service plans to provide widespread penalty relief for the late filing of certain tax and information returns for the 2019
Continue Reading Internal Revenue Service Announces Sweeping Penalty Relief for 2019, 2020 Tax Returns