...many taxpayers face real criminal exposure while genuinely disputing whether their conduct meets the legal standard for willfulness. Denying these taxpayers access to VDP, while allowing clearly willful taxpayers to...
The National Taxpayer Advocate recommends a law change to eliminate duplication. For tax professionals navigating the complexities of international tax law, few requirements are as redundant and potentially treacherous as...
...business ownership that leads to the most severe federal tax charges, because it is easier to prove tax violations. The Anatomy of the Tax Conspiracy The government’s case against Dr....
...Tax Professionals This case underscores several key areas where tax practitioners must remain vigilant when advising clients in the construction and general contracting sectors: IRC § 7201 (Tax Evasion): The...
Can a taxpayer’s good-faith reliance on tax preparation software serve as a defense against IRS penalties? The U.S. District Court for the Northern District of California recently addressed this issue...
...taxpayers and tax practitioners provide feedback about the proposed VDP changes?Taxpayers and tax practitioners may email questions or comments regarding the proposed VDP updates to vdp@ci.irs.gov with the subject line...
...the U.S. regarding withholding tax, and they declined to provide a Form W-9. Inaccurate Tax Returns: On Schedule B of their federal returns, the taxpayers checked “No” in response to...
The passage of the OBBBA has fundamentally reshaped the federal tax environment, moving many previously temporary incentives into the permanent fabric of the tax code. Here are some critical tips...
For tax practitioners, few issues in the international tax matters carry as much penalty risk as the reporting of foreign trust transactions and large foreign gifts. Under Internal Revenue Code...
...complex tax law interpretation and enforcement activity targeting the tax gap. Procedural Implications for Tax Professionals The integration of AI directly into the controversy workflow has tangible consequences for how...
...Employment Taxes). Importance for Tax Advisors For tax practitioners, this case is a stark reminder of the elevated risk in client representations involving employment tax non-compliance: Evidence of Willfulness: The...
...routinely handles in his tax-controversy practice. Take-aways Participants came away with: A fresh understanding of recent federal tax controversy trends and enforcement shifts. Practical guidance on how CPAs can proactively...
