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Internal Revenue Service Penalties

The United States Internal Revenue Service is a bureau of the United States Department of the Treasury. The IRS is charged with collecting revenue and enforcing the Internal Revenue Code.  
Vinson & Elkins LLP

Planning for IRS Audits in an Era of Uncertainty

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In its ongoing crusade against so-called “basis-shifting” transactions, the Internal Revenue Service has created widespread uncertainty regarding the tax treatment of routine transactions. For example, last year, the IRS...more

Gray Reed

You Can’t Hide – IRS Argues Willfulness Proven by Husband’s Conduct

Gray Reed on

It’s no secret that spouses, particularly in bad times, may hide things from one another. In fact, there are bodies of cases involving such marital behavior. However, we’ve gotten another recent reminder that such attempts...more

Allen Barron, Inc.

Omissions, Fraud, or False Information on a Tax Return

Allen Barron, Inc. on

What happens if you are accused by the IRS, the FTB, or another California tax agency regarding omissions, fraud, or false information on a tax return? The short answer is simple: failure to make a full, transparent, and...more

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

Bricker Graydon LLP

Is My Health Plan Affordable Enough?

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As employers increasingly struggle with rising health plan costs, the IRS has provided some good news. Recently, the IRS announced that the Affordable Care Act (ACA) affordability threshold will increase to 9.96% of household...more

Fox Rothschild LLP

The One Big Beautiful Bill Act Changes Employee Retention Tax Credit Program

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While the One Big Beautiful Bill Act made headlines for tax and spending cuts, it also contains significant changes to the federal government’s treatment of COVID era Employee Retention Tax Credit (ERC) claims — many of which...more

Jackson Walker

Employee Retention Credit (ERC) Changes under the One Big Beautiful Bill Act: Some Disallowances, Six-Year Statute of Limitations...

Jackson Walker on

Many ERC claimants are breathing a sigh of relief given the much toned-down version of the changes to the ERC enacted on July 4, 2025. As enacted, the One Big Beautiful Bill Act (the “OBBBA”) disallows all pending ERC claims...more

Eversheds Sutherland (US) LLP

IRS Removes Willfulness Checkbox from Form 14457, Easing Path for Voluntary Disclosures

In a significant policy shift, the IRS has revised Form 14457, Voluntary Disclosure Practice Preclearance Request and Application, the cornerstone of its Voluntary Disclosure Practice (VDP), by removing the controversial...more

Kelley Drye & Warren LLP

Simplified Option for Correcting Certain Retirement Plan Failures

Earlier this year, the U.S. Department of Labor (“DOL”) amended its Voluntary Fiduciary Compliance Program (“VFCP”) to provide retirement plan sponsors with a simplified option for correcting certain specified prohibited...more

Woodruff Sawyer

IRS Issues Affordability Percentage Adjustment for 2026

Woodruff Sawyer on

The Internal Revenue Service (IRS) has released Rev. Proc. 2025-25, which contains the inflation adjusted amounts for 2026 used to determine whether employer-sponsored coverage is “affordable” for purposes of the Affordable...more

Oberheiden P.C.

5 Key Considerations for Defending Against Low Income Housing Tax Credit (LIHTC) Fraud Allegations

Oberheiden P.C. on

Over its nearly 40-year history, the federal low income housing tax credit (LIHTC) program has been both a success story and a target for various forms of fraud. The LIHTC program has been credited with facilitating the...more

Ary Rosenbaum - The Rosenbaum Law Firm P.C.

Solo 401(k) Really Means Solo—So Don’t Be Surprised When You’re on Your Own

Let’s be honest: the Solo 401(k) is one of the great marketing wins of the retirement plan industry. It sounds easy. It sounds empowering. It sounds like freedom—no employees, no complex administration, no fuss. But let me...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

McDermott Will & Schulte

IRS roundup: June 18 – July 11, 2025

Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for June 18, 2025 – July 11, 2025. “One Big Beautiful Bill Act” tax provisions - On July 4, 2025, US President Donald...more

Allen Barron, Inc.

Are You Searching for An Experienced California or IRS Tax Attorney?

Allen Barron, Inc. on

Are you searching for an experienced California and IRS tax attorney? When legal professionals refer to California or IRS audits or tax issues, they are usually speaking of the types of interactions that a person or business...more

White & Case LLP

Tax-Exempt Organizations Should Prepare Now For An IRS Tax Audit

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It is an uncertain time to be a tax-exempt public charity or private foundation. The federal government has recently scrutinized certain tax-exempt organizations (see here), and draft congressional legislation proposed a tax...more

Bilzin Sumberg

Playing Battleship with the IRS: Did They Sink Our Battleship?

Bilzin Sumberg on

In prior posts, I discussed the dangers of playingBattleship with the IRS and how taxpayers scored “a hit”.  Recently, taxpayers took another turn in the game and scored another hit with the District Court’s recently issued...more

Freeman Law

Tax Cout in Brief | Christiansen v. Commissioner

Freeman Law on

The Tax Court in Brief - Freeman Law’s “The Tax Court in Brief” covers substantive Tax Court opinion, providing a brief of its decisions in clear, concise prose....more

Frost Brown Todd

Substantiating the Right to Claim QSBS Tax Benefits | Part 1

Frost Brown Todd on

Section 1202 provides an exclusion from capital gains when a stockholder sells qualified small business stock (QSBS), assuming all eligibility requirements are satisfied. Section 1045 provides for the tax-free rollover of...more

Vedder Price

IRS Extends Transitional Relief for Digital Asset Broker Reporting and Backup Withholding

Vedder Price on

On June 12, 2025, the Internal Revenue Service (IRS) released Notice 2025-33 which extends for an additional calendar year the transitional relief initially provided in Notice 2024-56 to brokers required to report digital...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

Allen Barron, Inc.

US Taxpayers and Expatriates May Need to File Offshore Disclosures and FBARs

Allen Barron, Inc. on

How many U.S. taxpayers and expatriates may need to file offshore disclosures and FBARs with the IRS? Should those who have not yet filed a disclosure application utilize the VDP (Voluntary Disclosure Program) or a...more

Bricker Graydon LLP

Don’t Forget About the IRS When Correcting Delinquent Plan Contributions

Bricker Graydon LLP on

Employers that do not timely deposit participant deferrals and loan contributions to their employer sponsored retirement plans can be subject to Department of Labor (DOL) penalties for breaching their fiduciary duties....more

Bilzin Sumberg

Do You Know Where Your Gift or Bequest Is Coming From? If Not, You May Be Subject to a Gift/Inheritance Tax and the Related New...

Bilzin Sumberg on

Pursuant to Internal Revenue Code Section (“Code §”) 2801, if you are a “U.S. Beneficiary” - who is the recipient of a gift or bequest from, or a distribution from a trust established by, a former U.S. citizen or former Green...more

Hone Maxwell

When is a U.S. International Tax Attorney Needed?

Hone Maxwell on

Individuals and businesses are frequently navigating transactions that span multiple countries. These transactions are often complex, as they navigate multiple jurisdictions’ unique — and often complicated — taxation systems....more

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