News & Analysis as of

Internal Revenue Service Internal Revenue Code (IRC) FinCEN

The United States Internal Revenue Service is a bureau of the United States Department of the Treasury. The IRS is charged with collecting revenue and enforcing the Internal Revenue Code.  
Freeman Law

Willful FBAR Penalties and the Excessive Fines Clause: District Court Says Context is Key

Freeman Law on

In its recent decision in United States v. Leeds, the United States District Court for the District of Idaho upheld the application of willful penalties against a deceased husband for failing to report certain foreign bank...more

Baker Botts L.L.P.

Taxpayer Assistance and Service Act – Tax Controversy Perspective

Baker Botts L.L.P. on

On January 30, 2025, a bipartisan group of US Senators released a discussion draft of the Taxpayer Assistance and Service Act (“TAS Act”), a legislative proposal that, if passed, could significantly alter tax controversy...more

ArentFox Schiff

The Big Six Items That Family Offices Need to Consider in 2025

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Across all industries, family offices and their owners and management teams face rapidly evolving challenges, opportunities, and risks in the dynamic environment that is 2025. Here are six issues that family offices should...more

Foodman CPAs & Advisors

NTA Addresses Overlap Reporting

On 1/8/25, the National Taxpayer Advocate (NTA) published its 2024 Annual Report to Congress and identified taxpayers’ problems and provided suggestions to further protect taxpayer rights and ease taxpayer burden. “By law,...more

Allen Barron, Inc.

A Foreign Trust Creates Complex IRS Reporting Requirements

Allen Barron, Inc. on

The IRS has clearly identified legitimate reasons why "U.S. Persons" would establish or maintain ownership in a foreign trust. However, a foreign trust creates complex IRS reporting requirements for US taxpayers who own a...more

Falcon Rappaport & Berkman LLP

Digital Assets Reporting Requirements Under Section 6050I

On January 16, 2024, the Treasury Department and Internal Revenue Service (“IRS”) announced that the agencies are postponing the implementation of increased reporting requirements for digital asset transactions under the...more

Paul Hastings LLP

Digital Asset Reporting is Here

Paul Hastings LLP on

Starting January 1, 2024, if you receive more than $10,000 in digital assets in one transaction (or a series of related transactions), you must now report those transactions to the Internal Revenue Service (“IRS”) and the...more

Proskauer - Regulatory & Compliance

CTA – The Large Operating Company Exemption – Not Everybody Can Be A “Big BOI”

In 2021, the Corporate Transparency Act (the “CTA”) was enacted into U.S. federal law as part of a multi‑national effort to rein in the use of entities to mask illegal activity. The CTA directs the U.S. Department of the...more

McDermott Will & Emery

West Coast Forum 2023 | Key Takeaways

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McDermott’s Private Client Practice led interactive discussions on a broad range of topics pertinent to ultra-high-net-worth families, their family office representatives and other advisors at our Private Client West Coast...more

Davies Ward Phillips & Vineberg LLP

Federal Courts Weigh in on the FBAR: Providing Relief from Outrageous Penalties

In this bulletin, we highlight two recent federal court cases in which U.S. taxpayers won major victories against the United States with respect to their obligations to report non-U.S. accounts on FinCEN Form 114 – Report of...more

Oberheiden P.C.

Tokenization Lawyer – 5 Reasons Why You Might Need One

Oberheiden P.C. on

What is Tokenization? Tokenization is the process of converting an asset into a token on the blockchain. It operates by dividing—or fractionalizing—the ownership of an asset (whether the asset is a piece of real estate or...more

ArentFox Schiff

Form 8300: When To File and What To Do With Cannabis Business Cash

ArentFox Schiff on

Cannabis businesses that regularly transact in cash need to strongly consider creating an internal policy to ensure that the Form is regularly completed and filed. The cannabis business is busier than ever and with all of...more

Faegre Drinker Biddle & Reath LLP

IRS Is Cleared to Serve John Doe Summons on Cryptocurrency Exchange

On April 1, 2020, the U.S. District Court for the District of Massachusetts granted the IRS leave to serve a “John Doe summons” on Boston-based Circle Internet Financial Inc. and its affiliates, the administrators of a...more

McDermott Will & Emery

Weekly IRS Roundup February 17 – 21, 2020

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Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of February 17 – 21, 2020. February 18, 2020: The IRS issued a revenue ruling providing various...more

McDermott Will & Emery

Weekly IRS Roundup December 23 – 27, 2019

McDermott Will & Emery on

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of December 23 – 27, 2019. December 20, 2019: The Department of the Treasury’s Financial Crimes...more

Holland & Knight LLP

Virtual Currency: The Taxman is Coming

Holland & Knight LLP on

Virtual currency transactions are now a prime focus of Internal Revenue Service (IRS) scrutiny. The IRS has numerous information-gathering tools to enforce its taxing power, including summons, artificial intelligence, data...more

Jones Day

Blockchain and Tax: Navigating Uncertainty

Jones Day on

Virtual currencies (often called cryptocurrencies) such as bitcoin are perhaps blockchain's best-known application. As these and other blockchain-based digital assets become more common, and attract more regulatory and...more

Foodman CPAs & Advisors

De-Risking 101

Foodman CPAs & Advisors on

Bank Secrecy Act of 1970 - Requires U.S. financial institutions to assist U.S. government agencies to detect and prevent money laundering by keeping records of cash purchases of negotiable instruments, and file reports...more

Goodwin

Financial Services Weekly News - September 2016 #3

Goodwin on

Editor's Note - Investment Company Institute Publishes FAQ on SEC No-Action Letter Regarding Auditor Independence. On September 23, the Investment Company Institute (ICI) published a memorandum (ICI Memo) responding to...more

McNees Wallace & Nurick LLC

Failure to Report Cash Payment Over $10,000 May Lead to Government Penalties

For about 25 years, under federal law, businesses have had an obligation to properly handle and report cash payments exceeding $10,000. Some confusion still exists, however, concerning to what types of businesses the...more

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