There has been a potentially landscape-altering decision out of the Fifth Circuit Court of Appeals (Court) regarding Reports of Foreign Bank and Financial Account (FBAR) penalties. In United States v. Bittner, that Court has held that each failure to report a qualifying account is a separate violation. This is a significant split from the Ninth [...]
Recently, I wrote an article for the Hennepin County Lawyer addressing some of the kinds of tax questions that non-tax attorneys receive from their clients. The text of this article is included below: Tax touches almost everything. As a tax attorney, this keeps my job very interesting. This also means that even non-tax attorneys likely [...]
Appearing in the October of 2021 issue of ALI CLE’s The Practical Lawyer is an article by Kathleen E. (Splett) Pfutzenreuter and Benjamin A. Wagner addressing a variety of tax topics that small and solo firm lawyers should be ready to answer. The tax topics covered include: when to talk to a tax accountant or [...]
The American Rescue Plan Act established the Restaurant Revitalization Fund (RRF) to provide support to eligible entities that suffered revenue losses related to the COVID-19 pandemic. Specifically, the U.S. Small Business Administration (SBA) will provide restaurants and other eligible entities with funding equal to their COVID-19 pandemic-related revenue loss up to $10 million per business [...]
The United States Department of Treasury (the Treasury) issued “The American Families Plan Tax Compliance Agenda,” detailing how the current administration intends to tackle the ever-looming noncompliance issue. This report was a follow up to the April of 2021 American Families Plan that included proposals that the administration announced to increase tax compliance. The Treasury [...]
Corporate income taxes are generally the responsibility of the corporation and not the individuals that own the corporation. However, there are circumstances where the Internal Revenue Service (IRS) can pursue an assessment of those obligations against the individuals. One of those methods of assessment is an alter ego and it is pursued when the IRS [...]
In January of 2018, the Internal Revenue Service (IRS) issued a press release advising delinquent taxpayers to negotiate reasonable alternatives to enforced collection action, or risk losing their passport. Please find more on that press release and the IRS’s initial approach to passport revocation here. Suffice to say, the initial process for passport revocation was [...]
The on-going COVID-19 pandemic has had a dramatic impact on the daily operations for the Internal Revenue Service (IRS). The IRS has appeared to have done its level best to provide taxpayers with options for securing vital documentation. Though, taxpayers attempting to obtain a lien release or certificate of discharge have experienced some delays in [...]
The proper classification of workers is a decision that is critical to the success or failure of many small businesses. This is especially true in light of the on-going public health crisis, where margins have been squeezed to their absolute limits. For more information relating to the classification of workers, please see these previous blog [...]
People often joke that the only certainties in life are death and taxes. Well, it turns out that, when it comes to the report of Foreign Bank and Financial Account (FBAR) penalties, death may have finally met its match. The Southern District of Florida issued a decision in United States v. Green, 2020 BL 165965 [...]