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
3/14/2023
/ Bittner v United States ,
FBAR ,
Foreign Bank Accounts ,
Income Taxes ,
Internal Revenue Code (IRC) ,
IRS ,
Offshore Funds ,
Reporting Requirements ,
SCOTUS ,
Tax Liability ,
Tax Penalties ,
Tax Returns
Less than a month after the heavily followed Green Valley Investors, LLC, et al., decision, the IRS issued proposed regulations to identify certain syndicated conservation easement transactions as listed transactions – this...more
12/21/2022
/ Administrative Procedure Act ,
Comment Period ,
Conservation Easements ,
Income Taxes ,
IRS ,
Proposed Regulation ,
Rulemaking Process ,
Tax Court ,
Tax Reform ,
Tax Shelters ,
Transaction Reporting
On November 9, 2022, in a 15-2 decision, the Tax Court held that the IRS improperly issued Notice 2017-10 in Green Valley Investors, LLC, et al. v. Commissioner of Internal Revenue, 159 T.C. No. 5. The Notice designated...more
11/16/2022
/ Administrative Procedure Act ,
Charitable Deductions ,
Conservation Easements ,
Income Taxes ,
Internal Revenue Code (IRC) ,
Investment ,
IRS ,
Partnerships ,
Tax Avoidance ,
Tax Court ,
Tax Deductions ,
Tax Penalties ,
Tax Planning
On September 21, 2022, the New York State Attorney General Tish James filed a civil lawsuit against former President Donald Trump and the Trump organization alleging fraud and misrepresentation. The Complaint described a...more
9/28/2022
/ Asset Valuations ,
Charitable Deductions ,
Conservation Easements ,
Department of Justice (DOJ) ,
Donald Trump ,
Government Investigations ,
High Net-Worth ,
Income Taxes ,
IRS ,
Misrepresentation ,
New York ,
Tax Deductions ,
Tax Fraud ,
Tax Shelters
Earlier this year, the Department of Justice filed the first criminal indictment of promoters, appraisers and accountants connected to an alleged scheme to create syndicated conservation easements. The move followed increased...more
Last week the Ninth Circuit issued a win for taxpayers in US v. Boyd, limiting penalties for non-willful violations of the requirement to file a Report of Foreign Bank and Financial Accounts (FBAR). ...more
4/5/2021
/ Failure-to-File ,
FBAR ,
Foreign Financial Accounts ,
Income Taxes ,
IRS ,
Offshore Funds ,
OVDP ,
Regulatory Violations ,
Reporting Requirements ,
Tax Evasion ,
Tax Penalties ,
Tax Planning