News & Analysis as of

Criminal Liability Internal Revenue Service Reporting Requirements

Womble Bond Dickinson

CIC Services, LLC v. Internal Revenue Service: Captive Insurance Wins a Battle, but the War Continues

Womble Bond Dickinson on

On Tax Day, May 17, 2021, in a unanimous opinion authored by Justice Kagan, the United States Supreme Court held that the Anti-Injunction Act ("AIA") does not bar a pre-enforcement challenge to the legality of an IRS-imposed...more

Kerr Russell

Challenge To IRS Notice Does Not Violate Anti-Injunction Act

Kerr Russell on

In a ruling with implications for retirement and tax planning generally, the U.S. Supreme Court has determined that, in certain circumstances, taxpayers can challenge reporting requirements before complying with the...more

Foodman CPAs & Advisors

Guilty From The Get-Go In The IRS Updated Voluntary Disclosure Program?

On June 20, 2019, the National Taxpayer Advocate (TA), an independent organization within the IRS that helps taxpayers and protects taxpayer rights, issued a final Report to Congress. A section of the report focused on the...more

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

Recent IRS Interim Guidance Provides That It Is Not Too Late For Your Willful Clients To Voluntarily Disclose Their Offshore...

The Internal Revenue Service has had a long-standing practice of providing taxpayers with potential criminal exposure a means to come into compliance with the law and potentially avoid criminal prosecution through the making...more

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