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Supreme Court Rules in Favor of Taxpayer in FBAR Case Penalty for Non-Willful Violations Apply on a Per-Report Basis

On Feb. 28, the U.S. Supreme Court ruled that non-willful penalties related to FBARs apply to each report filed, not on a per-account basis. The 5-4 decision resolved a split between the Fifth and Ninth circuits that focused...more

Inflation Reduction Act Expected to Become Law

Key Takeaways: ..The Senate voted 51-50 on August 7 to pass the Inflation Reduction Act. ..The legislation is expected to pass the House this week without changes and to be signed by President Biden. ..The...more

Per-Account or Per-Form Penalty?

Key Takeaways: ..The law regarding computation of FBAR penalties is unclear. ..The United States Supreme Court has agreed to hear a case to settle a conflict among the circuit courts. ..Until the Supreme Court...more

[Podcast] Intellectual Property Tax Considerations at Home and Abroad

Businesses that conduct operations both inside and outside of the United States and own U.S. and non-US-related intellectual property (e.g., patents, copyrights, trademarks, etc.) routinely face uncertainty about whether some...more

BEPS 2.0 - International Tax Reform Primer for SALT Experts

It can be a little intimidating for a state tax expert to stand around the water cooler with international tax experts that casually throw around terms like BEPS, Pillar 1, Pillar 2, Digital Services Taxes, OECD, GloBE, etc....more

M&A Considerations for Buyers of Targets with PPP Loans

While the Paycheck Protection Program (PPP), created under the Coronavirus Aid, Relief, and Economic Security (CARES) Act, has provided much-needed relief to small businesses in response to the COVID-19 pandemic in recent...more

Alert: IRS Issues New Guidance and FAQs on Virtual Currencies

On Oct. 9, the Internal Revenue Service (IRS) issued additional guidance regarding the taxation of cryptocurrency. The guidance comes more than five years after the IRS issued Notice 2014-21, the first and, until now, only...more

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