IRS Notice 2024-72, provides relief for individuals and businesses affected by terrorism in Israel.
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Penalties
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…
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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.
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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…
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