Daily Compliance News: May 7, 2025 the Private Lives Edition
The Presumption of Innocence Podcast: Episode 58 - Enforcement Priorities of the Second Trump Administration: IRS Investigations
Business Better Podcast Episode: Tax Audits, Investigations, and Global Enforcement - A Conversation with IRS Special Agent Jonathan Schnatz
The Presumption of Innocence Podcast: Episode 28 - Under the Microscope: Examining the Future of the ERC
The Presumption of Innocence Podcast: Episode 4 - Understanding the Employee Retention Credit
The Presumption of Innocence Podcast: Episode 2 - Avoid Falling Prey: The Dirty Dozen and Other Trending Tax Scams
Argentina: A Look at the Case of Lázaro Báez - Laundering the Proceeds of Corruption and Tax Fraud
Podcast: Cum-Ex Dividend Trade Investigations
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
In the late 1990s, former Atlanta Braves players John Smoltz and Ryan Klesko formed Big K Farms (“Big K”), a partnership that, over the years, acquired approximately 1,500 acres of land in Georgia for around $4 million. From...more
Two recent tax court cases paint an ominous picture for professionals and investors who participated in listed syndicated conservation easement transactions. Coming on the heels of the Fisher conviction and his lengthy...more
Recent Government actions suggest that third-party promoters and potentially hundreds of taxpayers may be entering into abusive trust arrangements aimed at unlawfully eliminating or deferring federal income taxes....more
While not as well-known as the Paycheck Protection Program, the Employee Retention Credit (“ERC”) program was another form of Covid relief provided by the federal government to businesses in 2020 and 2021. The ERC program...more
For some time, the IRS has cautioned taxpayers about filing false or fraudulent ERC claims. More recently, on September 14, 2023, the IRS issued a News Release, IR-2023-169, indicating that it would no longer process ERC...more
The Internal Revenue Service’s Criminal Investigation Division (IRS CI) is targeting tax preparers or the ones who prepare tax returns in 2022. IRS CI is focusing its efforts on tax preparers who underreport their clients’...more
In Chico v. Commissioner, the taxpayers challenged the Tax Court’s assessment of a fraud penalty. The Tax Court had imposed civil fraud penalties against the married taxpayers, finding clear-and-convincing evidence of fraud...more
It is tax season once again. While the Internal Revenue Service (IRS) has extended this year’s filing deadline to May 17, 2021 for individuals, businesses must still file by April 15, and all U.S. taxpayers must ensure that...more
Federal tax penalties have always been an IRS priority. But, perhaps more so today than three decades ago. For example, in 1987, the IRS reported that it had assessed penalties of approximately $14 billion. Compare that...more
The case of Salus Mundi Foundation et al v. Commissioner - On August 15, 2016, the Tax Court decided in Salus Mundi Foundation et al v. Commissioner, T.C. Memo. 2016-154, that two foundations were liable as transferees...more