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Reporting Requirements › Penalties › Tax Penalties

Womble Bond Dickinson

Micro-Captive Reportable Transaction Deadline Effectively Extended

Womble Bond Dickinson on

On Friday, April 11, 2025, the Internal Revenue Service issued Notice 2025-24 (the “Notice”), which waives applicable penalties under the Internal Revenue Code to participants in, and material advisors to, reportable...more

BakerHostetler

Supreme Court Rules in Favor of Taxpayer in FBAR Case Penalty for Non-Willful Violations Apply on a Per-Report Basis

BakerHostetler on

On Feb. 28, the U.S. Supreme Court ruled that non-willful penalties related to FBARs apply to each report filed, not on a per-account basis. The 5-4 decision resolved a split between the Fifth and Ninth circuits that focused...more

Holland & Knight LLP

Willful or Non-Willful? That Is the Question: IRS Rejects Non-Willful Certification

Holland & Knight LLP on

In Flint v. United States, 2022 WL 3593826 (Fed. Cl. 2022), the court held that the executors of an estate could not recover a six-figure "Title 26 miscellaneous offshore penalty" (MOP) the decedent paid to the Internal...more

Pillsbury Winthrop Shaw Pittman LLP

Lingering Questions About the San Francisco Gross Receipts Tax

Pillsbury Winthrop Shaw Pittman LLP on

The first installment payment for the new San Francisco Gross Receipts Tax was due April 30, 2014. Many questions about the new tax remain. While the City has provided some relief from installment underpayment penalties,...more

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