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 AbroadSenators Introduce Bipartisan Legislation to Significantly Improve Federal Tax Administration and Procedure
On February 26, 2026, Senate Finance Committee Chairman Mike Crapo (R-Idaho) and Ranking Member Ron Wyden (D-Oregon) introduced the Taxpayer Assistance and Service Act, a bipartisan legislative package proposing
Continue Reading Senators Introduce Bipartisan Legislation to Significantly Improve Federal Tax Administration and ProcedureCourt 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 PenaltiesFalse 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.
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 SplitThe 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 Olympics
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?IRS and Congress Expand Efforts to Address ERC Fraud
There are several new developments in the Internal Revenue Service’s ongoing campaign to combat false and fraudulent Employee Retention Credit (ERC) claims.
They include an indefinite extension of the agency’s
Continue Reading IRS and Congress Expand Efforts to Address ERC Fraud