The application of U.S. tax laws often turns on the meaning of “residency.” Although U.S. citizens and residents are subject to federal income taxes on their worldwide income, non-residents who are not U.S. citizens...
Congratulations to Six Meadows Collier Partners for their selection to The 2025 Inaugural Lawdragon 500 Leading Global Tax Lawyers. Lawdragon is extremely proud to recognize this talented and accomplished group of lawyers...
Late-Filing Penalties, Reasonable Cause, & Boyle
May 14, 2025
There are more than 100 penalties in the Internal Revenue Code. Each penalty varies in scope, but a common defense for almost all of them is “reasonable cause.” Where this defense applies, the IRS can’t impose...
Josh Ungerman is a contributing author of an article in the JOURNAL OF TAX PRACTICE & PROCEDURE
May 13, 2025
Josh Ungerman is a contributing author of the article, “General Ethical Considerations for Tax Controversy Attorneys and Proposed Amendments to Circular 230–Implications for Tax Practitioners”, with C....
Taxpayer Advocate Publishes Update on ERC
May 8, 2025
The IRS continues to struggle with processing and adjudicating ERC claims. Earlier today, Taxpayer Advocate published a Blog post with an update on the IRS’ progress (or lack thereof) and a call to the IRS to bring much...