Lauryn Hill's Tax Evasion a 'Battle for Survival': Lawyer
You may recall that earlier this year the IRS launched an initiative to pursue 125,000 “high-income, high-wealth” taxpayers who have not filed taxes since 2017. These were cases where the IRS received third party information...more
The Internal Revenue Service recently acknowledged systemic problems processing tax returns for deceased taxpayers who are due to receive a tax refund. The National Taxpayer Advocate (TAS) reported that the IRS experienced...more
If you’ve always thought your dealership couldn’t face any real trouble for not filing your EEO-1 reports, it’s time to think again. The feds just filed lawsuits against 15 employers across the country – including two...more
As we previously reported, the deadline for employers to submit their EEO-1 Component 1 reports is June 4, 2024. The federal regulations requiring reporting of the EEO-1 Component data also provide a mechanism for the EEOC...more
Employers who (allegedly) didn't file are being sued. The Equal Employment Opportunity Commission announced on Wednesday that it has filed suit against 15 employers in 11 states and in a variety of industries for failing to...more
In an unprecedented action, federal workplace law officials just filed suit against 15 employers in 10 states alleging that they failed to file their mandatory EEO-1 reports and asking the court to order the employers to do...more
When is a US Taxpayer required to disclose offshore accounts on an FBAR and IRS Form 8938? While many US taxpayers and expatriates have come to understand the requirements of the FinCEN Form 114 or FBAR, a surprising number...more
As the 2023 California pay data reporting cycle begins, a look at the California Civil Rights Department’s (CRD) recent pay data reporting enforcement actions provides a helpful reminder of the potential risk that exists for...more
Effective January 1, 2024, most Virginia community associations will be required to comply with the federal Corporate Transparency Act (“CTA”) and its regulations, unless a community association fits within one of the narrow...more
Although EEO-1 reports were due on December 5, employers that have not submitted and certified their data to the Equal Employment Opportunity Commission (EEOC) still have a chance to comply. Covered employers must submit and...more
What are the statute of limitations on an IRS audit and a California tax audit? There is a time limit, known as the “statute of limitations“, when the IRS and/or California must complete an audit of your tax returns. It is...more
Welcome to this edition of the FP Snapshot Manufacturing Industry, where we take a quick snapshot look at recent significant workplace law developments with an emphasis on how they impact employers in the manufacturing...more
On September 8, 2023, the IRS issued a News Release suggesting that FBAR compliance investigations and audits would heat up in the near future. For those unfamiliar with FBARs, federal law requires United States persons to...more
On September 29, the Financial Crimes Enforcement Network (“FinCEN”) entered into a consent order with Shinhan Bank America (“SHBA”), which imposed a $15 million dollar civil penalty against SHBA for allegedly willfully...more
In order to provide an overview for busy in-house counsel and compliance professionals, we summarize below some of the most important SEC enforcement developments from the past month, with links to primary resources. This...more
Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of June 5, 2023 – June 9, 2023...more
The recent Tax Court decision in Farhy demonstrates that clever and novel arguments can carry the day in complex tax litigation matters. In that case, the taxpayer stipulated that he: (1) had Form 5471 filing obligations...more
In a monumental opinion, the Tax Court recently held that the IRS lacks authority to assess penalties imposed by IRC § 6038(b)(1) or (2). In Fahry v. Commissioner, the taxpayer failed to file Forms 5471 reporting his interest...more
CFIUS has the authority to review any transaction that could result in foreign control of a US business, certain non-controlling investments and certain real estate transactions. This includes mergers, acquisitions, and joint...more
Taxpayers recently won a significant victory at the Supreme Court in a penalty case involving a non-willful failure to file a Report of Foreign Bank and Financial Accounts (“FBAR”) under the Bank Secrecy Act (the “BSA”)....more
In the federal income tax world, there are effectively two functions within the Internal Revenue Service (“IRS”). First, the IRS examines tax years and tax returns to determine whether the taxpayer has reported the correct...more
Brief Summary - An intermediate appellate court in Illinois held that defendant forfeited appellate review of expert testimony admitted at trial because he failed to file a post-trial motion on the issue. However, the...more
Summary: In this non-precedential opinion (see section 7463(b)), the Tax Court addresses an addition to tax for failure to pay pursuant to section 6651(a)(1) and (2). During 2017 Kemegue lost his job and experienced multiple...more
Publication indicates a more robust enforcement posture - On October 20, 2022, the U.S. Department of the Treasury (“Treasury”) released the first-ever Enforcement and Penalty Guidelines (the “Guidelines”) for the...more
Read part one of this article series here. Historically, information about small to mid-sized businesses has been within the exclusive province of state governments. As such, business entities have been able to maintain...more