News & Analysis as of

Internal Revenue Service Civil Monetary Penalty

The United States Internal Revenue Service is a bureau of the United States Department of the Treasury. The IRS is charged with collecting revenue and enforcing the Internal Revenue Code.  
Keating Muething & Klekamp PLL

Benefits Monthly Minute - August 2024

The August Monthly Minute highlights new IRS guidance addressing student loan matching programs, HHS’s increases to civil monetary penalties and Form 5330 paper filing updates....more

BakerHostetler

USDC Integrations Announced; Crypto Guidance Published by IRS, EU Banking Authority; Crypto Firm Consents to $8M Penalty; Illicit...

BakerHostetler on

USDC Report Published, Crypto Firms Announce USDC Integrations - Circle, the U.S. fintech company that manages the stablecoin USDC, recently released the “State of the USDC Economy” report, highlighting the “efforts to...more

Procopio, Cory, Hargreaves & Savitch LLP

IRS Has No Statutory Authority to Assess Penalties for IRS Form 5471

The U.S. Tax Court ruled recently that the U.S. Internal Revenue Service has no statutory authority to assess (or collect) civil penalties under IRC §6038(b) for failure to file or filing late IRS Form 5471, “Information...more

Cole Schotz

Important Supreme Court Decision will Decide how Non-Willful FBAR Penalties are Calculated

Cole Schotz on

This fall, the Supreme Court is set to hear an important case regarding the interpretation of the law that provides for penalties for failing to file an FBAR. The case will impact many taxpayers who have already been...more

Mitchell, Williams, Selig, Gates & Woodyard,...

U.S. Environmental Protection Agency Office of Criminal Enforcement, Forensics and Training: Environmental Crimes Case...

The United States Environmental Protection Agency (“EPA”) Office of Criminal Enforcement, Forensics and Training publishes an Environmental Case Crimes Bulletin (“Bulletin”) that summarizes publicized investigative activity...more

Bass, Berry & Sims PLC

Major Campaign Finance and Ethics Reform Bill: What PACs & Non-Profits Need to Know on July 1

Bass, Berry & Sims PLC on

The 112th General Assembly adjourned sine die on April 28th, 2022, but many of the successful measures will become effective on July 1st. Public Chapter 1087 – one of the most weighty and intricate bills – made changes to...more

Holland & Knight LLP

When IRS Penalty Assertions Are Unlawful

Holland & Knight LLP on

One of the most highly litigated issues in U.S. Tax Court is whether taxpayers are liable for certain penalties, additions to tax or additional amounts (each, a "penalty" and collectively, "penalties"). This should come as no...more

Freeman Law

The FBAR (Report of Foreign Bank and Financial Accounts): Everything You Need to Know

Freeman Law on

What is the Report of Foreign Bank and Financial Accounts (FBAR)? Congress enacted the statutory basis for the requirement to report foreign bank and financial accounts in 1970 as part of the “Currency and Foreign...more

Freeman Law

Court Strikes Down Largest Non-Willful FBAR Penalty Ever

Freeman Law on

I have previously written on the Bittner (E.D. Tex.) case in a prior Insight.  Briefly summarized, the taxpayer, Mr. Bittner, was a dual citizen of both Romania and the United States.  However, in 1990, he moved back to...more

Skadden, Arps, Slate, Meagher & Flom LLP

Highlights From the Recently Issued Proposed Regulations Under Sections 162(f) and 6050X

On May 13, 2020, the U.S. Treasury Department and Internal Revenue Service issued proposed regulations under Sections 162(f) and 6050X of the Internal Revenue Code regarding the disallowance of deductions for certain amounts...more

Katten Muchin Rosenman LLP

Bridging The Week - October 2019 #2

A broker-dealer and its chief executive officer settled charges brought in 2017 by the Securities and Exchange Commission that the firm facilitated manipulative conduct by a customer, despite being alerted by regulators and...more

Harris Beach PLLC

DOL Wage and Hour Audit: Lessons from the Backstretch

Harris Beach PLLC on

The recent U.S. Department of Labor Wage and Hour (WHD) investigation outcome of leading thoroughbred trainer Chad Brown has rocked the racing industry with the assessment of over $1.6 million in back wages and Civil Money...more

Jackson Walker

ERISA Alert: An Update on Health and Welfare and Retirement Plans

Jackson Walker on

Health and Welfare Plan Update - It is 9:00 p.m., do you know where your health plan data is? As IT systems continue to expand, and data is accessed, moved and stored in many new and different ways, the Office for Civil...more

Rosenberg Martin Greenberg LLP

Offshore Update: IRS Releases Memorandum Addressing Updates to Voluntary Disclosure Practice After Closing Offshore Voluntary...

Now, More than Ever, Taxpayers with Lingering Offshore Tax Non-Compliance Must Seek Professional Assistance - On November 20, 2018, the Internal Revenue Service (“the Service”) released a memorandum containing important...more

Rosenberg Martin Greenberg LLP

What to Do (and Not Do) to Resolve Your Offshore Tax Issues

In recent months, the Internal Revenue Service (“the Service”) began the process of issuing follow-up letters to taxpayers who either requested preclearance to participate in the Offshore Voluntary Disclosure Program (“OVDP”)...more

Bowditch & Dewey

A (Howard) Stern Reminder on Taxpayer Information Confidentiality

Bowditch & Dewey on

Howard Stern fans are accustomed to hearing the satellite radio personality rant about the federal government. Now, in an unusual twist of fate, Stern and the federal government are on the same side of a lawsuit that...more

Holland & Knight LLP

FinCEN Assesses Significant Penalty Against Casino for Bank Secrecy Act Violations

Holland & Knight LLP on

The Financial Crimes Enforcement Network (FinCEN) assessed on July 15 a civil money penalty in the amount of $2.8 million against Hawaiian Gardens Casino Inc., d/b/a The Gardens Casino, for Bank Secrecy Act (BSA) regulatory...more

Holland & Knight LLP

Department of Labor Increases Penalties for Certain ERISA Violations

Holland & Knight LLP on

The U.S. Department of Labor (DOL) published on July 1, 2016, an interim final rule adjusting the civil monetary penalties that it can enforce. These adjustments are the result of the Federal Civil Penalties Inflation...more

Blank Rome LLP

Confirming That No Country Is “Off Limits,” DOJ Secures Guilty Pleas From 2 Cayman Islands Financial Institutions for Tax Evasion

Blank Rome LLP on

In its first-ever conviction of a non-Swiss financial institution for tax evasion conspiracy, the Justice Department announced today that two Cayman Islands firms pleaded guilty in a U.S. court to conspiring to hide more than...more

Pillsbury Winthrop Shaw Pittman LLP

California Updates Conformity to Internal Revenue Code, Provides Large Corporate Understatement Penalty Relief

Governor Jerry Brown signed Assembly Bill 154 on September 30, 2015, updating California’s general conformity to the Internal Revenue Code and providing three new exceptions to the imposition of the Large Corporate...more

Foley & Lardner LLP

IRS Seeks Identities of Americans with Undisclosed Belize Bank Accounts

Foley & Lardner LLP on

Americans with secret accounts in Belize should take notice: the government is looking for you. The U.S. Department of Justice on September 15 filed a petition in federal court in Miami seeking permission to issue summonses...more

Epstein Becker & Green

Take 5 Newsletter: Five Hot Topics in Hospitality Law

Epstein Becker & Green on

ACA Final Regulations Provide Rules for Seasonal Employees - On February 10, 2014, the Internal Revenue Service ("IRS") promulgated final regulations for the ACA's employer "shared responsibility provisions" in IRS...more

Saul Ewing LLP

Death and Taxes? Recent Supreme Court Arguments in Gabelli v. SEC Concerning a General Statute of Limitations for Civil Fines May...

Saul Ewing LLP on

On January 8, the Supreme Court of the United States heard oral arguments in Gabelli v. S.E.C., 133 S. Ct. 97 (2012) on the question: By when must the government initiate an action to enforce a civil fine, penalty, or...more

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