Episode 384 -- Third-Party Risks and Sanctions
New FLSA Notice Standard, DOL’s PAID Program, Axed Wage and Hour Penalties - #WorkforceWednesday® - Employment Law This Week®
Compliance into the Weeds: A Deep Dive into Cadence Design Systems’ Export Control Violations
False Claims Act Insights - The Mathematics of Nuclear FCA Verdicts
Episode 379 -- Update on False Claims Act and Customs Evasion Liability
Compliance into the Weeds: Sanctions Compliance Failures: Lessons from Harman International and Interactive Brokers
Daily Compliance News: July 23, 2025 the Pardon in the Wind? Edition
Episode 378 -- Update on Export Controls and Sanctions Enforcement
False Claims Act Insights - Bitter Pills: DOJ Targets Pharmacies for FCA Enforcement
From Permits to Penalties: A Deep Dive Into Coastal Development Law
10 For 10: Top Compliance Stories For the Week Ending June 21, 2025
Daily Compliance News: June 16, 2025, The Golden Share Edition
PODCAST: Williams Mullen's Benefits Companion - Forfeitures Under Fire
GILTI Conscience Podcast | Navigating Brazil's New Transfer Pricing Landscape: A Shift to OECD Standards
Episode 371 -- DOJ's New Corporate Enforcement Program
REFRESH Nonprofit Basics: Federal Tax Filing Deadlines and Penalties
Episode 369 -- Stepping Into the Enforcement Spotlight -- Customs and Border Patrol and Import Enforcement
Insider Transaction Traps for the Unwary
Nonprofit Basics: Federal Tax Filing Deadlines and Penalties
JONES DAY PRESENTS®: Harmonizing Global Protections: The EU Trade Secret Directive
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
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
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
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
On January 30, 2025, a bipartisan group of US Senators released a discussion draft of the Taxpayer Assistance and Service Act (“TAS Act”), a legislative proposal that, if passed, could significantly alter tax controversy...more
Are you aware of the Taxpayer Bill of Rights? We are reminded, especially during tax season, that taxpayers have 10 essential rights when dealing with the Internal Revenue Service. The IRS expects its employees to understand...more
Following the 11th Circuit's ruling in Green Rock LLC v. IRS this past summer, the IRS has decided to cease its defense of post-American Jobs Creation Act (AJCA) reportable transaction notices. In an Action on Decision memo...more
More than 25 years ago, Congress enacted Internal Revenue Code Section 6751(b) to protect taxpayers from the IRS using penalties as a bargaining chip in an effort to coerce taxpayers to settle. Generally, Section 6751(b)...more
On April 3, 2023, the US Tax Court issued its opinion in Farhy v. Commissioner, holding that the Internal Revenue Service (IRS) lacked the statutory authority to both assess tax penalties under Internal Revenue Code (Code)...more
On April 11, 2023, the IRS issued proposed regulations concerning IRC § 6751(b). The statute requires that specific civil penalties must be personally approved (in writing) by the immediate supervisor of the individual making...more
In a monumental opinion, the Tax Court recently held that the IRS lacks authority to assess penalties imposed by IRC § 6038(b)(1) or (2). In Fahry v. Commissioner, the taxpayer failed to file Forms 5471 reporting his interest...more
The Tax Court’s decision setting aside IRS Notice 2017-10 for ignoring the APA’s notice and comment requirements has serious implications for other notices identifying listed transactions. Key Points: ..Notice 2017-10...more
The Tax Court’s recent decision in Walquist v. Commissioner, 152 T.C. No. 3, further clarified the application of the supervisor approval requirement under section 6751(b)(1), which has been a key issue since Chai v....more
How much were the late King of Pop’s name and image worth when he died? His estate put the figure at $2,105 but the IRS believes the value is at least $434 million. That’s a huge discrepancy and with penalties and interest...more