In federal tax controversy practice, managing the divergence between the IRS’s public-facing administrative declarations (website, FAQs, etc.) and its internal operational guidelines requires careful technical analysis. This distinction has become critical following the action of
The enforcement landscape surrounding the Paycheck Protection Program (PPP) has entered a highly aggressive enforcement phase. What began as an administrative process managed by the Small Business Administration (SBA) has transformed into a large enforcement
Five years after the Paycheck Protection Program closed, federal enforcement against New Jersey businesses is accelerating, not winding down. As 2022 statute extends the government’s window to pursue PPP fraud to ten years, the District
For tax professionals managing international compliance, few issues carry higher high-stakes risk than a late-filed or incomplete Form 3520, Annual Return To Report Transactions With Foreign Trusts and Receipt of Certain Foreign Gifts. Historically, the
The ongoing litigation over the Internal Revenue Service’s administrative authority to assess international information-return penalties has entered a new phase. For the past few years, the tax community has closely monitored structural challenges to the
The U.S. Court of Federal Claims recently issued a landmark ruling in Kwong v. United States, 179 Fed. Cl. 382 (2025), that profoundly alters the landscape of Internal Revenue Service (IRS) compliance enforcement for the
In an era of intensified international tax penalty enforcement, advising foreign-owned domestic corporations requires absolute precision. Among the most punitive enforcement mechanisms in the Internal Revenue Code is the Form 5472 filing requirement under Section
The boundary between civil tax non-compliance and criminal tax exposure has never been more porous. As the Internal Revenue Service aggressively expands its enforcement footprint utilizing advanced data analytics, practitioners must be prepared to handle
For tax professionals advising high-net-worth clients, structuring an estate plan requires a precise balancing act between minimizing estate tax exposure and maximizing income tax efficiencies. Central to this dynamic is the concept of the basis
As the Internal Revenue Service continues to expand its enforcement capabilities over foreign assets, international trust compliance has become a primary focus area for federal auditors. Navigating these structures requires a deep understanding of the
For high-growth startups and closely held businesses, Section 1202 Qualified Small Business Stock (QSBS) represents one of the most powerful tax minimization tools in the Internal Revenue Code. The ability to exclude up to 100%
International tax compliance remains one of the most heavily scrutinized areas of federal tax administration. For practitioners managing clients with cross-border structures, maintaining absolute compliance is essential to preventing catastrophic automated penalties. The Internal Revenue
