July 2019
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 IRS lived up to that truism in releasing a memorandum
The California FTB recently released a settlement initiative for taxpayers involved in microcaptive or syndicated conservation easement transactions. Taxpayers who enter into the settlement program will not be able to claim any tax benefits associated with the respective transaction. Taxpayers
Wednesday, September 27, 2023 | Philadelphia
Join leading practitioners from throughout the U.S. for an afternoon of lively discussion covering the latest developments in the field, presented by Fox Rothschild’s national White-Collar Criminal Defense & Regulatory Compliance Practice Group.
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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 in a
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 has already ramped up to crack down on tax compliance.
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.
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, the IRS concluded that taxpayers must obtain a ‘qualified appraisal’
On the morning of Dec. 20, 2022, we finally got a look at the language being negotiated in the 4,155 page Omnibus spending bill. Buried in the bill is new language relating to donations of conservation easements by pass-through entities.
In a major victory before a 17-judge panel of the U.S. Tax Court, a Fox Rothschild litigation team led a successful challenge to an IRS rule and secured the reversal of certain penalties imposed in four consolidated cases involving a
The Presumption of Innocence Podcast: Episode Sixteen
How can you ensure you’ve prepared your case for the best chance at success on appeal should the verdict not lean in your client’s favor? Marsha Piccone, a former judge on the
