Resources

Managing Partner, Anthony Daddino was quoted in a recent Tax Notes article written by Kristen Parillo on March 13, 2023 titled, “Limited Partner Status Requires Functional Analysis, IRS...

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...