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
Continue Reading IRS Going All in on Use of ArtificiaI Intelligence
It is a truism that agencies required to publicly release documents sometimes hold off on releasing those documents until a Friday afternoon, in the hopes it will be overlooked. The
Continue Reading IRS is coming for NIL collectivesIn 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
Continue Reading Tax Court Rules IRS Cannot Assess Certain International Reporting Penalties
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
Continue Reading Increase in IRS Funding Leading to More Audits of Public Charities
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
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 CryptocurrencyThe 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 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
Continue Reading The Presumption of Innocence Podcast – Episode Two
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
Continue Reading IRS Restricts Levy Actions Involving EIP or PPP Funds
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
Continue Reading Fox Rothschild’s Fourth Annual Federal Tax Controversy Summit