In a monumental opinion, the Tax Court recently held that the IRS lacks authority to assess penalties imposed by IRC § 6038(b)(1) or (2). In Fahry v. Commissioner, the
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Increase in IRS Funding Leading to More Audits of Public Charities
As part of the Inflation Reduction Act, the IRS will receive a nearly $80 billion funding increase, including more than $45 billion for enforcement, over the next decade. Audit staff
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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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IRS Cracks Down on Charitable Contributions of Cryptocurrency
By Adam R. Young and Brian Bernhardt
On January 13, 2023, the IRS issued Chief Counsel Memorandum 202302012 (the “CCM”) establishing new rules for donations of cryptocurrency. In the CCM
Continue Reading IRS Cracks Down on Charitable Contributions of CryptocurrencyInternal Revenue Service Unveils “Dirty Dozen” Tax Scams for 2022
The Internal Revenue Service has announced the first installment of its annual “Dirty Dozen” list of tax scams. Published every year, the “Dirty Dozen” comprises the twelve most prevalent tax
Continue Reading Internal Revenue Service Unveils “Dirty Dozen” Tax Scams for 2022The Presumption of Innocence Podcast – Episode Two
The Presumption of Innocence is a new podcast on hot topics in the world of white-collar criminal and regulatory enforcement featuring Matthew S. Adams and Matthew D. Lee, Co-Chairs
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IRS Restricts Levy Actions Involving EIP or PPP Funds
In recognition of the continuing economic hardship caused by the COVID-19 pandemic, the Internal Revenue Service is easing its collection activities to avoid the seizure of bank accounts containing either
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Fox Rothschild’s Fourth Annual Federal Tax Controversy Summit
On January 12, 2021, please join members of Fox’s Tax Controversy team for a review of recent developments in federal tax controversy and civil and criminal tax enforcement, as well
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Internal Revenue Service’s LB&I Division Announces Compliance Campaign Focused on TCJA
The Internal Revenue Service’s Large Business & International Division has announced another compliance campaign, its 64th such campaign since the first set of campaigns was unveiled in 2017. This latest
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Upcoming Webinar: Federal Tax Enforcement in the Age of COVID-19
On Tuesday, April 21, 2020, at 9:30 a.m. ET, Fox Rothschild partner Matthew D. Lee will present a webinar entitled “Federal Tax Enforcement in the Age of COVID-19.” The COVID-19
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