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Internal Revenue Service Supreme Court of the United States Tax Returns

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.  
Gray Reed

Balancing Privacy and Tax Enforcement in the Digital Age

Gray Reed on

The Internal Revenue Service was aware of significant underreporting of cryptocurrency on tax returns and used one of its investigative tools (i.e., a John Doe summons) in 2016 to seek financial information on thousands of...more

Rivkin Radler LLP

Challenge to Collection Due Process? Will Supreme Court Affirm IRS’s Offset of Valid Refund With Disputed Tax Liability?

Rivkin Radler LLP on

Earlier this year the IRS announced that, as part of its larger compliance efforts begun last fall under the Inflation Reduction Act, the agency’s stepped-up enforcement activity with respect to high wealth, high income...more

Rivkin Radler LLP

Missing the Tax Court’s 90-Day Deficiency Deadline – Now What?

Rivkin Radler LLP on

Over the years, I have observed there is only one thing that a taxpayer fears more than being notified by the IRS that their income tax return for a particular taxable year has been selected for audit, and that is being...more

ArentFox Schiff

Investigations Newsletter: Court Unseals Charges Alleging Nearly $15 Million in Fraudulent PPP Loans

ArentFox Schiff on

Court Unseals Charges Alleging Nearly $15 Million in Fraudulent PPP Loans - Earlier this week, federal prosecutors in the Southern District of New York announced the unsealing of a criminal complaint charging six...more

Cadwalader, Wickersham & Taft LLP

Supreme Court Hands Taxpayers a Victory in FBAR Penalty Case

Taxpayers recently won a significant victory at the Supreme Court in a penalty case involving a non-willful failure to file a Report of Foreign Bank and Financial Accounts (“FBAR”) under the Bank Secrecy Act (the “BSA”)....more

Polsinelli

Major Win For Taxpayers: SCOTUS Limits FBAR Penalties to Per Report Not Per Financial Account

Polsinelli on

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

Rosenberg Martin Greenberg LLP

Affordable Care Act Battle Rages On: Fourth Circuit Holds Individual Mandate Is a Tax in Bankruptcy

As originally enacted, the Affordable Care Act (“ACA”) required most people to maintain health insurance. Those who did not maintain the required insurance were obligated to pay a “shared responsibility payment” (“SRP”),...more

Holland & Hart LLP

Fortify attorney-client privilege over dual-purpose communications before Supreme Court decides In Re Grand Jury

Holland & Hart LLP on

...A communication must be made for the purpose of legal advice to be protected from disclosure by the attorney-client privilege. If legal advice is not the purpose of the communication, the attorney-client privilege does not...more

Brownstein Hyatt Farber Schreck

Taxation & Representation, April 26, 2022

SCOTUS Denies New York v. Yellen. The U.S. Supreme Court announced on Tax Day it would not hear a constitutional challenge to the $10,000 deduction limit on state and local taxes (SALT) enacted under the Tax Cuts and Jobs Act...more

Lewitt Hackman

Return to Windsor: A Novel Tax Code Correction

Lewitt Hackman on

Here’s the next chapter in the saga known as Edith Schlain Windsor v. The United States of America. (For a quick recap, please read Tax & Estate Planning – Small Win for Same Sex Couples?). Two representatives of the state...more

Thomas Fox - Compliance Evangelist

This Week in FCPA-Episode 56

This week, Jay and I have a wide-ranging discussion on some of the week’s top compliance related stories. We discuss: 1. The Kokesh case at the US Supreme Court is significant for SEC enforcement of the FCPA around profit...more

Troutman Pepper

All Federal Benefits Apply To Same-Sex Marriages

Troutman Pepper on

Recently, the U.S. Supreme Court ruled unconstitutional Section 3 of the Defense of Marriage Act (DOMA), which, for federal purposes, defined marriage as between one man and one woman. United States v. Windsor, 570 U.S. ____...more

Nossaman LLP

The IRS Says Yes, We're Married...Now What?

Nossaman LLP on

The U.S. Supreme Court in June struck down the Defense of Marriage Act (DOMA) provision preventing the federal government from recognizing a legally-valid marriage of a same-sex couple, and the Internal Revenue Service...more

BakerHostetler

Treasury Department Guidance on Same-Sex Spousal Status Requires Employers to Take Immediate Action on Employee Benefit Plans

BakerHostetler on

Earlier this summer, following the Supreme Court's issuance of the landmark case, United States v. Windsor, which held Section 3 of the Defense of Marriage Act (DOMA) to be unconstitutional, we published an Executive Alert...more

Proskauer - Employee Benefits & Executive...

IRS Adopts a “Place of Celebration” Rule in Implementing the U.S. Supreme Court’s Windsor Decision

On August 29, 2013, the U.S. Department of the Treasury and the Internal Revenue Service issued important guidance for employers and employees relating to the impact of the Windsor decision on employee benefit plans....more

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