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IRS Authority to Assess Certain Foreign Information Return Penalties Restored by D.C. Circuit

The U.S. Court of Appeals for the District of Columbia Circuit (D.C. Circuit) on May 3, 2024, reversed the U.S. Tax Court (USTC) in Alon Farhy v. Commissioner, No. 23-1179 (D.C. Cir. May 3, 2024) by holding that...more

How Can the Same Right Create 2 Separate Property Interests?

The Internal Revenue Service (IRS) can file a lien and levy on any and all of a taxpayer's property (and rights to property) regardless of how the property is held or titled. 26 U.S.C. ยง 6321. Whether the item is a taxpayer's...more

When Is a Tax Return "Filed"?

In Notice 2004-45, 2004-2 C.B. 33, the IRS put taxpayers who were asserting to be bona fide residents of the U.S. Virgin Islands (USVI) and who were not following the requirements of meeting the applicable bona fide residency...more

IRS Fishing Expedition Is Successful and Raises Important Attorney-Client Privilege Concerns

The attorney-client privilege is one of the bedrocks of the legal profession. It permits communications between a client and an attorney to remain privileged. The U.S. Supreme Court has stated that by assuring...more

Tangible Basis of Property: Who Decides?

The American Recovery and Reinvestment Act of 2009 (ARRA) Section 1603 provided a cash grant (Grant) for "specified energy property" (as defined in ARRA Section 1603(d)). Specified energy property, within the meaning of ARRA...more

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