News & Analysis as of

Enforcement Actions Tax Liability

Vinson & Elkins LLP

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

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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

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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

DLA Piper

Customs Agent Ordered to Pay GBP1m in Import VAT Relating to its Customer's Imports

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Roseline Logistics Ltd (Roseline) acted as a Customs agent for QP Trading Limited (QPTL) and made 32 import declarations between January and May 2022. Roseline claimed postponed VAT accounting (PVA) on QPTL's behalf in each...more

Fox Rothschild LLP

Ruling Allows IRS to Automate Review of Employee Retention Credit Claims

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A federal court has upheld the IRS’s right to use automated tools to review Employee Retention Credit (ERC) claims, rejecting a challenge brought by two tax preparation firms. In ERC Today LLC v. McInelly, the U.S. District...more

Eversheds Sutherland (US) LLP

House tax bill proposes major changes to the Employee Retention Tax Credit (ERTC)

On May 12, 2025, the Republicans on the House Committee on Ways and Means introduced a broad tax reform bill that includes sweeping changes to the Employee Retention Tax Credit (ERTC), also commonly known as the ERC. Chief...more

Fox Rothschild LLP

DOJ Seeks Injunction Barring Promotion of Monetized Installment Sales

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An installment sale occurs when property is disposed of and at least one payment is received after the tax year of the disposition. See I.R.C. § 453. Under a standard installment sale, the buyer makes scheduled payments to...more

Rivkin Radler LLP

Observations on Charities, Taxes, and Cash Flow

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Few provisions of the Code have a single, clear meaning that leaves no room for interpretation. Even many of those that, on the surface, appear fairly straightforward, are usually open to alternative “understandings.”...more

Farrell Fritz, P.C.

Relocating? Be Sure to Add the IRS to Your Change of Address Checklist

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In a recent decision, the U.S. District Court for the Central District of California held that the Internal Revenue Service (“IRS”) did not violate Internal Revenue Code (“IRC”) Section 7433 or related regulations when it...more

Fleurinord Law PLLC

Real Housewives Star Peter Thomas’ Payroll Tax Evasion Case: What Every Small Business Owner Must Know

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From Reality TV to Real-Life Tax Fraud: Peter Thomas’ $2.5 Million Scandal - Peter Thomas, best known for his appearances on The Real Housewives of Atlanta, was sentenced on December 19, 2024, to 18 months in federal prison...more

Cadwalader, Wickersham & Taft LLP

2024 Crypto Tax Year in Review

The crypto tax space saw significant developments in 2024. As 2025 ushers in new regulatory shifts (as our colleagues discussed here), tax changes may be on the horizon. In anticipation, this review revisits crypto tax...more

DLA Piper

Chile's Internal Revenue Service Publishes It's 2025 Tax Schemes Catalog

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Each year, the Internal Revenue Service of Chile (SII) updates its Tax Schemes Catalog. This guide contains a list of operations that may be declared elusive by applying the General Anti-Elusiveness Rule. The catalog's...more

McDermott Will & Schulte

IRS Roundup January 20 – 31, 2025

Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the weeks of January 20, 2025 – January 24, 2025, and January 27, 2025 – January 31, 2025....more

ArentFox Schiff

Investigations Newsletter: International Mining and Energy Disputes Monitor: 2025 Issue No. 1

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This inaugural issue of ArentFox Schiff’s publication on international mining, energy, and infrastructure disputes aims to provide insights and practical information to general counsels and senior executives of companies...more

Rivkin Radler LLP

Business Owner Borrows from Their Private Foundation – A Different Form of “For Profit Philanthropy”?

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Many successful business owners attribute some part of their success to their community. For some of these owners, it is not enough to simply acknowledge this “debt”; they feel an obligation to share some of their financial...more

Latham & Watkins LLP

Treasury Finalizes Controversial Regulations on IRS Penalty Oversight, but Debate Continues

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Section 6751(b), designed to ensure supervisory oversight amid rising penalty assertions in settlement negotiations, has been contentious due its ambiguity, and the final regulations may not resolve the debate....more

DLA Piper

Romania - VAT: Extension of the Applicability of RO e-Invoicing System to B2C Transactions - Monthly Indirect Tax Alert – January...

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1 January 2025 marked the entry into force of the obligation for Romanian established taxpayers that carry out taxable operations in Romania to report in the Romanian invoicing System the invoices issued in B2C transactions....more

Farrell Fritz, P.C.

Federal Tax Controversies and the Appeals Resolution Process

Farrell Fritz, P.C. on

The Taxpayer First Act (“TFA”), which was signed into law on July 1, 2019, makes the most significant changes to administrative procedures since the Internal Revenue Service Restructuring and Reform Act of 1998. In addition...more

Rivkin Radler LLP

Not Aware of Your Business Partner’s Tax Situation? Maybe You Should Be

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If you’ve worked with the owners of closely held businesses for even just a few years, you have realized they are only half joking when they complain about having the government as a partner. Consider how much federal, state,...more

Freeman Law

National Taxpayer Advocate’s Annual Report Highlights Issues Plaguing the IRS

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In her annual report to Congress for 2024, National Taxpayer Advocate (“NTA”) Erin M. Collins identified the processing of Employee Retention Credits (“ERCs”), the administration of civil penalties, and changes to the...more

Rodemer Kane Attorneys at Law

Tax Fraud: Simple Mistake or Serious Crime?

Taxes. Except for maybe the CPAs and tax professionals, the word alone elicits groans and sighs from even the most cheerful among us. While the necessity of taxes is rarely disputed, navigating the complex world of tax...more

Gray Reed

How to Haunt the IRS: Daugerdas v. Commissioner

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In a bench opinion dated September 27, 2024, the Tax Court sustained a Notice of Federal Tax Lien but not the proposed levy against Daugerdas, a convicted tax shelter promoter in home confinement in Illinois....more

Cadwalader, Wickersham & Taft LLP

First Stand-Alone Crypto Tax Fraud Case Leads to Guilty Plea

On September 12, 2024, the U.S. Department of Justice (“DOJ”) announced that Frank Richard Ahlgren III pleaded guilty to filing a false tax return underreporting gains from selling $3.7 million in Bitcoin. As we discussed...more

Buckingham, Doolittle & Burroughs, LLC

What to Do If Your Business Receives a Tax Audit

When your business receives an audit engagement letter, don’t panic. While an audit may be time-consuming, costly, and invasive, having an experienced advocate on your side to navigate you through the process and represent...more

Cadwalader, Wickersham & Taft LLP

Crypto: Give Unto Caesar What Is Caesar’s

Earlier this year the U.S. Department of Justice (“DOJ”) brought USA v. Ahlgren, its first crypto case with tax evasion allegations unrelated to another crime, demonstrating the DOJ’s willingness to pursue stand-alone crypto...more

Gray Reed

IRS Seeks to Enforce Summons Related to Deferred Sales Trust

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We have previously spoken about monetized installment sales (“MISTs”) on Dollars & Sense.  According to the IRS, these structures typically seek to defer gains associated with the sale of an appreciated asset through the use...more

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