Lauryn Hill's Tax Evasion a 'Battle for Survival': Lawyer
You may recall that earlier this year the IRS launched an initiative to pursue 125,000 “high-income, high-wealth” taxpayers who have not filed taxes since 2017. These were cases where the IRS received third party information...more
The Internal Revenue Service recently acknowledged systemic problems processing tax returns for deceased taxpayers who are due to receive a tax refund. The National Taxpayer Advocate (TAS) reported that the IRS experienced...more
When is a US Taxpayer required to disclose offshore accounts on an FBAR and IRS Form 8938? While many US taxpayers and expatriates have come to understand the requirements of the FinCEN Form 114 or FBAR, a surprising number...more
What are the statute of limitations on an IRS audit and a California tax audit? There is a time limit, known as the “statute of limitations“, when the IRS and/or California must complete an audit of your tax returns. It is...more
On September 8, 2023, the IRS issued a News Release suggesting that FBAR compliance investigations and audits would heat up in the near future. For those unfamiliar with FBARs, federal law requires United States persons to...more
Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of June 5, 2023 – June 9, 2023...more
The recent Tax Court decision in Farhy demonstrates that clever and novel arguments can carry the day in complex tax litigation matters. In that case, the taxpayer stipulated that he: (1) had Form 5471 filing obligations...more
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 taxpayer failed to file Forms 5471 reporting his interest...more
Taxpayers recently won a significant victory at the Supreme Court in a penalty case involving a non-willful failure to file a Report of Foreign Bank and Financial Accounts (“FBAR”) under the Bank Secrecy Act (the “BSA”)....more
In the federal income tax world, there are effectively two functions within the Internal Revenue Service (“IRS”). First, the IRS examines tax years and tax returns to determine whether the taxpayer has reported the correct...more
Summary: In this non-precedential opinion (see section 7463(b)), the Tax Court addresses an addition to tax for failure to pay pursuant to section 6651(a)(1) and (2). During 2017 Kemegue lost his job and experienced multiple...more
The American Institute of CPAs (AICPA) has applauded the Internal Revenue Service for granting automatic penalty relief related to select 2019 and 2020 returns, but asked for two tweaks to the process: The group wants...more
The senior living industry was hit hard by the Covid-19, and the IRS recently announced relief for people or businesses who filed their 2019 or 2020 tax returns late as a result. If your business was subject to failure to...more
Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of September 6, 2022 – September 9, 2022...more
It’s a man-bites-dog story when the tax man gives money away. That’s exactly what the Internal Revenue Service (IRS) intends to do. In a seemingly unprecedented move, the IRS announced plans to return approximately $1.2...more
The IRS just announced, in releasing Notice 22-36, that it will be automatically issuing an estimated $1.2 billion in refunds or credits related to failure to file penalties assessed against taxpayers on a broad range of 2019...more
The Internal Revenue Service plans to provide widespread penalty relief for the late filing of certain tax and information returns for the 2019 and 2020 tax years. According to Notice 2022-36, this latest penalty relief...more
On June 21, 2022, the United States Supreme Court agreed to hear a dispute involving split decisions among the circuit courts on non-willful penalties. The Fifth Circuit parted ways with the taxpayer friendly decision of the...more
We previously provided an overview of the time limits imposed on the Internal Revenue Service (IRS) for assessing federal tax. The general rule is that the IRS must assess tax within three years from the later of the due date...more
Charles Lieber, former chair of the chemistry and chemical biology department at Harvard University, was convicted on December 21st by a jury on two counts of making false statements to federal authorities, two counts of...more
The IRS uses the information it collects to detect, prevent, and reduce noncompliance and fraud. The US Government accountability Office (GAO) produced a Tax Administration Report on December 2020 (Better Coordination Could...more
The 2022 discretionary funding request (request) made by the Biden Administration will invest in a “fair and robust” tax system that includes tax compliance enforcement directed at High Income and High Net Worth Individuals...more
Last week the Ninth Circuit issued a win for taxpayers in US v. Boyd, limiting penalties for non-willful violations of the requirement to file a Report of Foreign Bank and Financial Accounts (FBAR). ...more
Federal tax penalties have always been an IRS priority. But, perhaps more so today than three decades ago. For example, in 1987, the IRS reported that it had assessed penalties of approximately $14 billion. Compare that...more
El 3 de diciembre del 2020, el IRS publicó “Cómo el IRS prioriza el trabajo de cumplimiento en los no declarantes de altos ingresos a través de esfuerzos nacionales e internacionales” en el Estudio titulado “Closer Look”. El...more