REFRESH: Loot and Private Foundation Rules – Part 2
Nonprofit Quick Tip: State Filings in North Carolina and South Carolina
Business Better Podcast Episode: Tax Audits, Investigations, and Global Enforcement - A Conversation with IRS Special Agent Jonathan Schnatz
REFRESH Nonprofit Basics: Election Year Issues for Private Foundations and Public Charities - Private Foundation Advocacy
REFRESH Nonprofit Basics: Election Year Issues for Private Foundations and Public Charities - Legislative Lobbying and Advocacy Rules for Public Charities
REFRESH Nonprofit Basics: Election Year Issues for Private Foundations and Public Charities - Candidate Campaign Intervention
Domestic Tax Planning - Podcast with Janathan Allen
Tax Liability Insurance Products: A Hidden Gem in the Transactional Lawyer’s Tool Box
JONES DAY PRESENTS®: Tax Implications of Telehealth as Remote Services Become Norm
Podcast: Got Mail? What to Do When the IRS Contacts You [More with McGlinchey, Ep. 42]
Tax Legend Fred Goldberg Shares Insights From His 50 Years in Tax Law
Let's Talk What to Bring to Your First Family Law Appointment
The Renoir Spelling Bee
Eastward Bound: Cannabis Market Trends, Taxation, and More
Why Cannabis Related Businesses Must Consider Legal and Tax Issues
2021 House Ways And Means Tax Proposals
Coronavirus in the Workplace
How are Your Company’s Taxes Impacted by the New U.S. DOL Rule on Independent Contractors?
KNOCK YOURSELF OUT - RESUSCITATING TAXPAYERS WITH BUYER'S REMORSE!
On April 15, the IRS released Notice 2024-33 (the “Notice”), offering limited relief from tax penalties for underpaying estimated income taxes arising from a corporation’s alternative minimum tax (“AMT”). The AMT imposes a...more
United States citizens and residents are often not aware of the myriad of foreign information return filing obligations that exist under federal tax laws. For example, buried within the Code are reporting obligations...more
A hearing is scheduled for September 11, 2023 for interested persons and organizations to provide testimony on proposed regulations on the timing and approval process for penalties. Section 6751(b) provides that...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 prior post, I discussed the dangers of playing Battleship with the IRS. Recently, taxpayers made a move and scored a hit with the Tax Court’s recently issued decision in Alon Farhy v. Commissioner, 160 T.C. No. 6 (April...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
After years of litigation, the United States Supreme Court, in Bittner v. United States, 598 U.S. ____ (2023), determined that the penalty for a non-willful failure to file a Report of Foreign Bank and Financial Accounts...more
Summary: In this non-precedential opinion (see section 7463(b)), the Tax Court addresses whether or not to uphold an accuracy-related penalty assessed to taxpayer, Ashenafi Getachew Mulu (Mulu). Mulu hired David...more
Taxpayer and petitioner, Joseph Decrescenzo (“Petitioner”) belatedly filed returns of income for seven years at issue (2007-2013). The IRS determined various differing deficiencies as to the years at issue and notified...more
Summary: During 2016, Ryan Mining (Mining) was employed by Tasco, Inc. (Tasco), and it issued him Form W–2, Wage and Tax Statement, reporting wages of $116,000, no federal income tax withheld, Social Security tax withheld of...more
Short Summary: After an examination by a Revenue Agent, the IRS issued to the taxpayers a notice of determination of income tax deficiencies, a tax addition, and an accuracy-related penalty. In closing the examination, the...more
Eleventh Circuit Sides with Ninth Circuit on Section 6751(b) Circuit Split - Introduction: Section 6751(b) and the Timing of Supervisory Approval of a Penalty - The Eleventh Circuit’s decision in Kroner v. Commissioner,...more
Many people, myself included, can sometimes be accused of poor penmanship. As our paperwork becomes more and more electronic, we write less and less down with pen and paper. However, a recent decision from the tax court may...more
Tax penalties are always a hot topic here. The Internal Revenue Service (IRS) has a large arsenal when it comes to grounds for asserting penalties on income tax deficiencies, ranging from the common 20% penalty under Internal...more
Although the government bears the burden of production for penalties, this often involves nothing more than showing that the penalties were properly assessed. Penalty relief is usually only given when the taxpayer can marshal...more
All kinds of penalties are being assessed by the Internal Revenue Service (IRS) against taxpayers, and more can be expected in the future. In 1954 there were 13 penalties in the Internal Revenue Code, and now there are more...more
The IRS is vigorously litigating cases involving conservation easements they believe are abusive. One such case was Plateau Holdings, LLC v. Comm’r, T.C. Memo 2020-93 (Plateau I). In that case the Tax Court denied the entire...more
On November 30, 2021, the Fifth Circuit parted ways with the taxpayer friendly decision of the Ninth Circuit that non-willful penalties are capped at $10,000 per FBAR filing instead of the $10,000 per unreported bank account...more
Accuracy-related penalties under section 6662 are among the most common penalties in the Tax Code. As a result, they are often at issue in tax litigation against the IRS. That raises the question: What are the burdens of...more
On September 13, 2021, the Congressional House Ways and Means Committee introduced 880 plus pages of legislative tax proposals to help fund the House’s proposed $3.5 trillion stimulus package. Below are tax proposals relevant...more
Promoting abusive tax shelters. Taxpayers and tax return preparers should be aware of the various penalties that exist and can be assessed for certain actions (or nonactions). One such action includes promoting an abusive tax...more
The 35% penalty under I.R.C. section 6677 for failing to report a distribution from a foreign trust applies against a person who is both the beneficiary and grantor/owner of a foreign trust. At least, that is now the rule...more
The recent case of In re Bowman, Case No. 20-11512, Section A (Bankr. E.D. La., July 12, 2021) addresses an interesting intersection of tax and bankruptcy law. Specifically, it looks at the issue of whether bankruptcy courts...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
Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of September 9 – 13, 2019. September 9, 2019: The IRS released a revision to its Internal Revenue...more