News & Analysis as of

Tax Liability Penalties

Ballard Spahr LLP

Big Changes to Washington State Department of Revenue’s Voluntary Disclosure Agreement (VDA) Program

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At last week’s Washington State Tax Forum, the Washington Department of Revenue announced, in a presentation led by Ballard Spahr’s Aaron Johnson, that the Department is making significant and meaningful changes to its...more

Vinson & Elkins LLP

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

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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

Allen Barron, Inc.

The Risk of California FTB Audits is Increasing

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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

Mayer Brown

Brazilian Internal Revenue Service Publishes New Rules for Low-Value Debts and Debts Up to BRL 50 Million

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On July 7, 2025, the Brazilian Internal Revenue Service (IRS) published Notices No. 4/2025 and No. 5/2025, introducing new modalities of tax settlement by adhesion within the scope of administrative tax litigation, with...more

Freeman Law

Tax Cout in Brief | Christiansen v. Commissioner

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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

McDermott Will & Schulte

What to know about Illinois’s 2025 amnesty programs

On May 31, 2025, the Illinois General Assembly passed House Bill 2755, which contains three amnesty programs the state estimates will substantially increase its coffers. Illinois Governor JB Pritzker signed the bill into law...more

Frost Brown Todd

Substantiating the Right to Claim QSBS Tax Benefits | Part 1

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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

Vedder Price

IRS Extends Transitional Relief for Digital Asset Broker Reporting and Backup Withholding

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On June 12, 2025, the Internal Revenue Service (IRS) released Notice 2025-33 which extends for an additional calendar year the transitional relief initially provided in Notice 2024-56 to brokers required to report digital...more

DLA Piper

Belgian VAT Authorities Publish New Circular Letter Regarding Late Input VAT Recovery

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Seven years after relevant judgments from the CJEU, the Belgian VAT authorities now (broadly) allow the recovery of input VAT beyond the standard Belgian limitation period of three years, subject however to strict conditions....more

Allen Barron, Inc.

You Need an Experienced Tax Attorney when Tax Issues Strike

Allen Barron, Inc. on

Why do you need an experienced tax attorney when tax issues strike? What do you need to know about communications with the IRS and California's tax agencies?...more

DLA Piper

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

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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

Freeman Law

Risks in Avoiding State Tax Obligations

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When a business has been hit with substantial tax liability, it can often be tempting to pack things up and abandon the business. Often, taxpayers consider the possibility of opening a new business in its place, as a means...more

Bricker Graydon LLP

Don’t Forget About the IRS When Correcting Delinquent Plan Contributions

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Employers that do not timely deposit participant deferrals and loan contributions to their employer sponsored retirement plans can be subject to Department of Labor (DOL) penalties for breaching their fiduciary duties....more

Hone Maxwell

When is a U.S. International Tax Attorney Needed?

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Individuals and businesses are frequently navigating transactions that span multiple countries. These transactions are often complex, as they navigate multiple jurisdictions’ unique — and often complicated — taxation systems....more

Freeman Law

Posts, Profits, & Penalties | Tax Law & Social Media | Part 4

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As discussed in Part 2, there are many ways social media creators earn income. Social media income, like all income, needs to be reported on federal tax returns....more

Amundsen Davis LLC

Does My Company Qualify for Wisconsin’s Voluntary Disclosure Program?

Amundsen Davis LLC on

Taxes and their applicable laws can be confusing for even the most savvy businesspeople. For any number of reasons, businesses and individuals fall out of compliance with tax reporting requirements and become exposed to...more

Allen Barron, Inc.

Why You Need a Lawyer for an IRS Audit

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Why do you need a lawyer for an IRS audit? Have you received an IRS audit notification (IRS form letter 2205-A, 2205-B, or 566)? What do you need to know?...more

Farrell Fritz, P.C.

Responding to NYS Tax Department Letters: Key Steps for Taxpayers

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Earlier this month, New York State Department of Taxation and Finance published a press release explaining what taxpayers should do when they receive a letter from the Tax Department. The press release outlined several...more

Freeman Law

Penalties for Failures with Respect to Forms 1099 and Other Information Returns

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Section 6721 of the Internal Revenue Code imposes a penalty on any person who fails to file a Form 1099 or other information return to the IRS by the required filing date, fails to include all information required to be shown...more

Freeman Law

Posts, Profits, & Penalties | Tax Law & Social Media | Part 3

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The IRS Has Eyes - Having any presence on social media—even sans influencer following or income—can and may be used against you by the IRS. Have you ever Googled yourself? You will likely be shocked at how much...more

Ary Rosenbaum - The Rosenbaum Law Firm P.C.

Being aggressive on your mistakes could be a bad idea

Many moons ago, I got a call from a bank with a problem. For two decades—yes, twenty years—they had failed to include bonuses as part of plan compensation. The kicker? They were supposed to. This wasn’t a gray area; the plan...more

Littler

Employers Are Obligated to Comply with Tax Law Despite Increase in Frivolous Tax Arguments

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In the recent United States Tax Court case O’Connor v. Commissioner of Internal Revenue, Judge Arbeit sanctioned the petitioner for advancing frivolous arguments contesting the authority of the IRS to assess tax....more

Eversheds Sutherland (US) LLP

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

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

Farella Braun + Martel LLP

Insider Transaction Traps for the Unwary

Welcome to EO Radio Show - Your Nonprofit Legal Resource. I'm Cynthia Rowland, and today I'm joined by David Sacarelos, a principal at Baker Tilly. We do a deep dive into the penalties under the Internal Revenue Code sections...more

Mayer Brown

Caractérisation d’un établissement stable dans le domaine du digital en présence d’une activité occulte

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Le Conseil d’Etat confirme l’existence d’un établissement stable et caractérise une activité occulte en l’absence de déclaration de cet établissement en France par application de l’article L. 169 du Livre des procédures...more

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