For many years, the IRS has offered administrative pathways for taxpayers seeking to return to compliance with federal tax reporting obligations. These initiatives generally allow taxpayers to re-enter the reporting system...
Category: Blog
The IRS continues to take an aggressive approach concerning reasonable cause relief associated with late international information returns. More recently, these attacks have centered on arguments that taxpayers do not...
$2.3m Penalty for a Swiss Bank Account Might be Excessive, Even When the Account Was Opened in the Name of the Taxpayer’s Dog
June 23, 2026
The IRS uses huge civil penalties as an aggressive enforcement weapon in the international arena, but an opinion issued by the U.S. Court of Appeals for the 11th Circuit reminds us that the government’s ability to punish is...
Fifth Circuit Upholds Penalties Associated with Deathbed FLP Planning
June 17, 2026
By Eric D. Marchand, Blog
Family limited partnerships (FLPs) are utilized by estate planning attorneys for a variety of reasons, including, the efficient transfer of wealth and asset protection. FLPs, when done right, can also position an estate for...
Federal tax law has long allowed theft loss deductions. And even though the Tax Cuts and Jobs Act of 2017 (TCJA) substantially limited theft loss deductions for tax years after 2017, the IRS released a Chief...