News & Analysis as of

Tax Audits Penalties Statutory Interpretation

Harris Beach Murtha

IRS Files First Response to Common Industry 280E Arguments

Harris Beach Murtha on

The Internal Revenue Service (IRS) recently filed its first written response to arguments used widely by cannabis taxpayers as justification for not paying Section 280E taxes. The closely-watched U.S. Tax Court case, New...more

White & Case LLP

Courts and Congress Say IRS Must Approve Civil Tax Penalties in Writing Before They Are Asserted

White & Case LLP on

For the last decade, the IRS has proactively asserted discretionary civil tax penalties that can be as high as 40 percent of the proposed tax liability. Oftentimes, the IRS has used penalties as bargaining chips to get...more

Holland & Knight LLP

Same Statute, Same Form, Different Penalties: Welcome to FBAR Litigation

Holland & Knight LLP on

The "Report of Foreign Bank and Financial Accounts" (FBAR) penalty has been the subject of much litigation. This Holland & Knight alert focuses on the non-willfulness element of 31 U.S.C. § 5321(a)(5)(B). Both the U.S. Court...more

3 Results
 / 
View per page
Page: of 1

"My best business intelligence, in one easy email…"

Your first step to building a free, personalized, morning email brief covering pertinent authors and topics on JD Supra:
*By using the service, you signify your acceptance of JD Supra's Privacy Policy.
- hide
- hide