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Tax Audits Penalties Tax Liability

Offit Kurman

Top Audit Red Flags Businesses Shouldn’t Ignore

Offit Kurman on

My recent blog, So, The IRS Has Selected Your Return for Audit, discussed the four types of IRS audits. What factors may trigger an audit of a business’s income tax return?...more

FBT Gibbons LLP

Avoiding IRS Accuracy Penalties for a Substantial Underpayment of Tax

FBT Gibbons LLP on

There are over 150 types of penalties in the Internal Revenue Code (IRC). One frequent penalty that the Internal Revenue Service (IRS) asserts is the accuracy penalty under IRC Section 6662....more

Allen Barron, Inc.

Why the IRS Requests Information During an Audit — and Why the “Why” Matters More Than the Request Itself

Allen Barron, Inc. on

If you have received an IRS Letter of Notification advising you that your return has been selected for audit, the most important thing to understand is this: the audit has already begun. The first communications with the IRS...more

Mayer Brown

Supplementary Law No. 225/2026: Taxpayers' Defense Code

Mayer Brown on

On January 9, 2026, the final text of the Supplementary Law ("LC") No. 225/2026 was published in the Official Gazette of the Federal Government, which launches the Taxpayers´ Defense Code (the “Code”), establishing...more

Opportune LLP

IRS Tax Controversy Guide: Navigating the Process from Notice to Resolution

Opportune LLP on

Tax controversy is a term that describes disputes between taxpayers and taxing authorities, most commonly the Internal Revenue Service (IRS), regarding the amount of tax owed or the application of tax laws. These...more

DLA Piper

Lifecycle of a transaction: tax disputes on intra-group debt

DLA Piper on

Where there is potential for a tax dispute, it is crucial to map your position early: proactively building a “defence” file can best prepare taxpayers for HMRC enquiries when they arise years later. Originally Published in...more

Rivkin Radler LLP

Escape from New York – It’s Not That Easy

Rivkin Radler LLP on

It’s not at all unusual to encounter the owner of a New York business who dreams about leaving the State. The reasons often given for the desired move include, among others, the cost of doing business in New York, the State’s...more

Vinson & Elkins LLP

Whose Fraud Is It Anyway? The Expanding Reach of the Fraud Exception to the Statute of Limitations on Tax Assessment

Vinson & Elkins LLP on

Earlier this year, we unpacked the elements of tax fraud, how the Internal Revenue Service (IRS) approaches fraud in civil and criminal settings, and the penalties and consequences that can follow. That discussion focused on...more

Cole Schotz

Snowbirds’ Wings Clipped by New York Tax Appeals Tribunal

Cole Schotz on

In a recent decision, the New York Tax Appeals Tribunal issued a sharp reminder to ‘snowbirds’ that changing domicile is about substance, not paperwork. In Matter of John J. Hoff & Kathleen Ocorr-Hoff, DTA No. 850209 (N.Y....more

Vinson & Elkins LLP

Civil Tax Fraud: Should 75 Percent Appear Too Small, Be Thankful the IRS Doesn’t Take It All

Vinson & Elkins LLP on

Mistakes happen, including when it comes to reporting and paying taxes. And for taxpayers and their advisors, those mistakes can lead to costly consequences, as the Internal Revenue Code (“Code”) allows the Internal Revenue...more

Allen Barron, Inc.

The Risk of California FTB Audits is Increasing

Allen Barron, Inc. on

Did you know that the number of California FTB audits is increasing when compared to the trend of IRS audits in 2025? The California Franchise Tax Board, or FTB, has recently invested in advanced data processing systems and...more

Allen Barron, Inc.

You Need an Experienced Tax Attorney when Tax Issues Strike

Allen Barron, Inc. on

Why do you need an experienced tax attorney when tax issues strike? What do you need to know about communications with the IRS and California's tax agencies?...more

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