News & Analysis as of May 9, 2025

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The United States Supreme Court is the highest court of the United States and is charged with interpreting federal law, including the United States Constitution. The Court's docket is largely discretionary with only a limited number of cases granted review each term. The Court is comprised of one chief justice and eight associate justices, who are nominated by the President and confirmed by the Senate to hold lifetime positions. less -

The Corporate AMT’s Crypto Problem Poses Constitutional Hazards

Latham & Watkins LLP on 1/16/2025

Under recent accounting rule changes, unrealized crypto gains must generally be reported on income statements, but questions arise about the alignment of the new Corporate Alternative Minimum Tax with constitutional tax...more

Supreme Court Hands Taxpayers a Victory in FBAR Penalty Case

Cadwalader, Wickersham & Taft LLP on 3/22/2023

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

Major Win For Taxpayers: SCOTUS Limits FBAR Penalties to Per Report Not Per Financial Account

Polsinelli on 3/14/2023

After years of litigation, the United States Supreme Court, in Bittner v. United States, 598 U.S. ____ (2023), determined that the penalty for a non-willful failure to file a Report of Foreign Bank and Financial Accounts...more

Post-DMA, Federal Court of Appeals Broadly Interprets Jurisdictional Limitations of Anti-Injunction Act

McDermott Will & Emery on 9/3/2015

Earlier this month, the United States Court of Appeals for the D.C. Circuit held in Florida Bankers Ass’n v. U.S. Dep’t of the Treasury, No. 14-5036 (D.C. Cir. Aug. 14, 2015) that the Anti-Injunction Act (AIA, codified at 26...more

Highway Funding Bill Includes Significant Changes to Tax Rules

Morgan Lewis on 8/10/2015

Unexpected changes in FBAR, corporate and partnership returns, and statute of limitations and mortgage reporting tax rules are embedded in funding bill H.R. 3236. When US President Barack Obama extended funding for...more

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