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 clause of the Eighth...more
On January 13, 2023, the IRS issued Chief Counsel Memorandum 202302012 (the “CCM”) establishing new rules for donations of cryptocurrency. In the CCM, the IRS concluded that taxpayers must obtain a ‘qualified appraisal’ if...more
“Nothing can be said to be certain, except death and taxes.” ? Benjamin Franklin.
This familiar phrase resonates for daily fantasy sports (DFS) operators following the release of a July 23, 2020 Internal Revenue Service...more