The Tax Court has invited amicus briefs and will address the codified meaning of the economic substance doctrine after increased IRS use of the doctrine to challenge taxpayer transactions.
In a July 19, 2024, order in...more
The IRS is making good on its promise to step up enforcement on large partnerships that issue more than 100 annual K-1s and have more than $100 million in assets. As noted in this Latham Client Alert, the IRS’s renewed focus...more
The IRS’s simmering concern with pass-through entities is heating up, with IRA funds earmarked for increased personnel, AI, and other resources for partnership audits. ...more
The Third Circuit challenges the long-held view that the timing requirements for Tax Court review of a notice of deficiency preclude any extension or delay of the filing deadline.
Culp v. Commissioner is the first case in...more
The Tax Court’s decision setting aside IRS Notice 2017-10 for ignoring the APA’s notice and comment requirements has serious implications for other notices identifying listed transactions.
Key Points:
..Notice 2017-10...more
Taxpayers must act quickly to determine if further action is necessary to obtain relief. Delinquent returns must be filed on or before September 30, 2022.
...more
The ruling provides a new avenue for parties to bring pre-enforcement challenges to IRS rules and regulations.
Key Points:
..In CIC Services v. IRS, the US Supreme Court allowed a pre-enforcement challenge to an IRS...more
6/17/2021
/ Administrative Procedure Act ,
Anti-Injunction Act ,
CIC Services LLC v IRS ,
Criminal Liability ,
Criminal Penalties ,
Enforcement ,
Federal Jurisdiction ,
Internal Revenue Code (IRC) ,
IRS ,
Notice and Comment ,
SCOTUS ,
Subject Matter Jurisdiction ,
Tax Penalties
Updated guidance relieves most tax deadlines, provides new procedures for claiming tax relief, and addresses communications with the IRS during the widespread shutdown.
...more
Notice 2020-18, expanded by Notice 2020-20, provides welcome economic relief from filing and payment obligations for certain federal taxes; however, traps for the unwary exist.
Tax Deadline – Key Points:
..On March 20,...more
News release details operational changes and additional administrative relief for taxpayers facing uncertainty due to COVID-19.
Key Points:
..The IRS is prioritizing taxpayer and IRS personnel safety and security with...more
Notice 2020-18 provides welcome economic relief from filing and payment obligations for certain federal income taxes; however, traps for the unwary exist.
Tax Deadline – Key Points:
..On March 20, 2020, the Internal Revenue...more
3/26/2020
/ Coronavirus/COVID-19 ,
Corporate Taxes ,
Filing Deadlines ,
Income Taxes ,
IRS ,
Office Closures ,
Popular ,
Relief Measures ,
State of Emergency ,
Tax Court ,
Time Extensions
LB&I has announced compliance initiatives regarding the Section 965 Transition Tax, Repatriation via Foreign Triangular Reorganizations, and Virtual Currency transactions.
Key Points:
..The IRS continues its efforts to...more
While FBAR reporting rules are frequently misunderstood, US persons have several options to correct mistakes, before the government learns of the non-compliance.
June 30th is the annual deadline for filing a Foreign...more
The first non-prosecution agreement signals expanded US tax enforcement opportunities at home and abroad.
The US Department of Justice (DOJ) has announced the first non-prosecution agreement (NPA) with BSI, SA, (BSI)...more
4/16/2015
/ Banks ,
BSI SA ,
Department of Justice (DOJ) ,
FATCA ,
FFI ,
Foreign Banks ,
IRS ,
Non-Prosecution Agreements ,
OVDP ,
Swiss Banks ,
Tax Evasion
You have implemented FATCA; what comes next? Will your company be the next witness in a US tax investigation? Financial institutions around the world must now prepare to respond to anticipated inquiries and investigations as...more
8/12/2014
/ Banking Sector ,
Banks ,
Chief Compliance Officers ,
Department of Justice (DOJ) ,
Enforcement ,
FACTA ,
FATCA ,
FFI ,
Financial Institutions ,
Government Investigations ,
IRS ,
OVDP ,
Popular ,
Transparency
The changes give taxpayers who mistakenly failed to report foreign assets a simpler path back to tax compliance.
On June 18, 2014, the Internal Revenue Service (IRS) announced major modifications to the terms of its...more
Miriam Fisher, global Co-chair of the firm's Tax Controversy Practice, focuses her practice on federal tax controversy and litigation, including complex civil and criminal tax matters. Fisher spoke at the November 6, 2013...more