Last June, I wrote a blog post on a 9th circuit panel opinion in Seaview Trading LLC v. Commissioner, where the panel, in a 2-1 decision, reversed the Tax Court on the meaning of a “filed” return. The panel...
One of my favorite things to do is snow ski. I’ve been doing it for a long time and try to go on a couple of ski trips every year. In fact, I just returned from a trip with a couple of friends including my colleague Alan...
Firm Partner, Josh Ungerman was quoted in a recent Tax Notes article written by Andrew Velarde, “Supreme Court Hands Huge Victory to Non-Willful FBAR Violators” regarding the Supreme Court decision in the...
When a taxpayer omits a foreign account from an FBAR form and that omission is nonwillful, federal law can still impose a steep monetary penalty. Originally that penalty was capped at $10,000, but the law requires that the...
In a prior blog post, HERE, I discussed how both the IRS Examination Division and the IRS Criminal Investigation Division were starting to focus on Employee Retention Credits (ERC) and ERC promoters. In a recent...
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