False Claims Act: Implied Certification Theory
On 10/24/24, the National Taxpayer Advocate shared on its NTA Blog that the IRS has discontinued its policy of automatically imposing penalties for late submissions of Form 3520, which pertains to foreign gifts and...more
The Internal Revenue Service (IRS), in a recently released memorandum from the Office of Chief Counsel (Chief Counsel Memorandum), has taken the position that the Employer Shared Responsibility Payment (ESRP) imposed by...more
The U.S. income tax system is based on the idea of voluntary taxpayer compliance. It is the taxpayer’s responsibility to report all reportable worldwide income. Some people attempt to evade paying taxes by failing to report...more