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
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?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 FraudThe IRS has announced a new Voluntary Disclosure Program (VDP) offering businesses a limited-time opportunity to repay improperly claimed Employee Retention Credits at a discount while avoiding penalties and interest. The VDP requires businesses to repay only 80% of the improper credits they received and has an application deadline of March 22, 2024.
Continue Reading New IRS Voluntary Disclosure Program Lets Businesses Repay Questionable Employee Retention Credits at a Discount
In its most recent effort to fight fraudulent and improper Employee Retention Tax Credit (ERC) claims, on December 6, 2023, the IRS announced it will be notifying an initial group
Continue Reading IRS Rejects 20,000 Employee Retention Tax Credit Claims, Plans to Offer New Voluntary Disclosure ProgramThe IRS recently announced that it will offer certain employers an opportunity to withdraw Employee Retention Credit (ERC) claims if they are concerned about their accuracy. Qualifying employers may be
Continue Reading Amid Fraud Investigations, IRS Offers Employers an Opportunity to Withdraw Inaccurate Employee Retention Credit ClaimsBy Matthew Adams, Joseph DeMaria and Marissa Koblitz Kingman
Recent remarks to the American Bar Association’s National White Collar Criminal Defense Institute by Deputy Attorney General Lisa O. Monaco serve
Continue Reading Biden Justice Department Emphasizes Focus on Prosecuting Individual Corporate Criminal Misconduct
With April 15 just around the corner, the Justice Department’s Tax Division has issued its annual public warning to would-be tax cheats. It is no secret that the Justice Department
Continue Reading With April 15 Fast Approaching, DOJ Tax Division Issues Annual Tax Crimes Warning
The IRS has been cracking down on conservation easement transactions for over ten years. Nevertheless, taxpayers have continued to claim charitable contribution deductions attributable to the donation of conservation easements
Continue Reading Conservation Easements: A Year End Review
On September 29, 2018, the Internal Revenue Service closed for good the long-running Offshore Voluntary Disclosure Program (OVDP), its hugely successful tax amnesty program for undisclosed offshore financial assets. Since
Continue Reading Despite Closure of OVDP, Offshore Tax Evasion Crackdown Marches On