Every January, businesses race to issue Forms W-2, 1099, and 1099-NEC, but a small typo in a Social Security Number (SSN) or Taxpayer Identification Number (TIN) can turn into a
Continue Reading Back to the Future: Tax Edition — Correcting SSN/TIN Issues Before the IRS Repossesses the DeloreanTax Controversy Litigation
No Points for Participation: Passive Activity Rules and Loss Limitations
By Adam Young on
Classroom participation points may boost a child’s grade in history class, but merely raising your hand won’t get you far with the IRS. The passive activity loss rules under I.R.C.
Continue Reading No Points for Participation: Passive Activity Rules and Loss LimitationsHorse Breeding and Training Expense Deductions? Tax Court Says Neigh
By Adam Young on
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 NeighThe Taxpayer Assistance and Service Act: Title III: Judicial Review
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
By Jonathan Wasser on
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
By Brian Bernhardt on
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
By Brian Bernhardt on
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
By Isaac Hoenig & Adam Young on
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 Split