Penalties, Enforcement Actions, Tax Liability

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

Vinson & Elkins LLP on 8/8/2025

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

The Risk of California FTB Audits is Increasing

Allen Barron, Inc. on 7/18/2025

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

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

DLA Piper on 6/12/2025

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

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

Eversheds Sutherland (US) LLP on 5/19/2025

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

Observations on Charities, Taxes, and Cash Flow

Rivkin Radler LLP on 4/11/2025

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

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

Fleurinord Law PLLC on 2/28/2025

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

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

Latham & Watkins LLP on 2/7/2025

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

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

Freeman Law on 1/20/2025

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

Penalties › Enforcement Actions › Tax Liability

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