The IRS issued final rules for the penalty imposed on material advisers for failing to provide the IRS a list of advisees with respect to reportable transactions.
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TOPICS / PROCEDURE
Collections, Liens & Levies
Legislation Permanently Bans Internet Taxes, Increases Failure-to-File Penalty
Congress passed the Trade Facilitation and Trade Enforcement Act of 2015, making permanent the moratorium on states and
localities taxing Internet access.
Final Regulations Clarify $10,000-Per-Day Material Adviser Penalty
The IRS issued final rules on how to apply the $10,000-per-day penalty under Sec. 6708 when a material adviser fails to provide the Service a list of advisees with respect to reportable transactions.
CDP Notice of Determination Valid If Actually Received
The Tax Court held that a notice of determination from a collection due process hearing is valid for purposes of starting the period in which a taxpayer must file a petition with the Tax Court if the notice is actually received by the taxpayer.
Streamlined Filing Procedures for Disclosing Foreign Assets and Income
Qualifying taxpayers who failed to report foreign-source income and can prove their conduct was not “willful” could enjoy significantly reduced penalties.
PATH Brings Changes to Federal Penalty Computations
This item discusses the PATH legislation’s immediate impact on certain federal penalty computations.
IRS Made “Initial Determination”
IRS could impose penalty because the examiner had made an initial determination that the penalty applied.
Passport Revocation and Third-Party Debt Collection Provisions Enacted
Passports can be denied to any person whom the IRS certifies as having seriously delinquent tax debt.
Guidance Contains Inflation Adjustments for 2015 Information Return Penalties
A recently enacted law requires penalties for failing to file certain information returns to be adjusted for inflation. The latest adjustments are announced in this guidance.
IRS Provides Guidance on FBAR Penalties
The guidance provides procedures to ensure consistency and efficiency in the IRS’s administration of the FBAR compliance program.
Tax Court: Thou Shalt Not Promote False Tax Shelters
The Tax Court upheld the IRS’s imposition of penalties against a couple for marketing and promoting tax shelters based on the use of a corporation sole.
CPAs May Be Responsible for Clients’ Payroll Tax Penalties
The Erwin case is an important reminder that an accountant can be held liable for a client’s unpaid employment taxes.
Money Can’t Buy Love, but It Can Keep You Out of Prison
Seventh Circuit upheld a district court’s decision to spare Beanie Babies billionaire prison time for evading taxes by hiding assets in a Swiss bank account.
IRS Proposes Rule Updates and Clarifications to Penalty for Nondisclosure of Reportable Transactions
The IRS issued proposed regulations that would update and clarify the rules regarding the penalty for failure to disclose reportable transaction information.
Construction Contractor Hammered on Trust Fund Penalty
The Tax Court held that a responsible person taxpayer was not entitled to currently not collectible status for her liability attributable to a trust fund recovery penalty and that adequate protection payments made to the IRS by her wholly owned corporation could not be applied to her liability.
The Threat of Parallel Investigations: When Civil Isn’t Civil
This article examines recent developments in parallel civil and criminal investigations as they have been reinvented over the past decade.
Relief From Penalties for Late-Filed International Information Returns
Penalties apply for failure to report the information required under Secs. 6038 and 6038A by failing to timely file Form 5471, 5472, or 8865. There are two procedural paths for a taxpayer that files a late form.
Congress Makes Changes to Tax Code in Trade Preferences Act
The Trade Preferences Extension Act of 2015 contains tax provisions in addition to the trade measures that were the focus of the bill.
IRS Grants Penalty Relief to Taxpayers Who Received Incorrect Health Care Forms
To ease the filing burden for taxpayers who received late or incorrect Forms 1095-A, the IRS announced that it will provide penalty relief for taxpayers.
Former Partner Liable for Trust Fund Penalty
A taxpayer who asserted he was no longer a partner in a business during the periods at issue was nevertheless held to be a responsible person and liable for the 100% penalty for failure to pay over withheld employment taxes.
INDIVIDUALS
Current Developments in Taxation of Individuals: Part 1
This update surveys recent federal tax developments involving individuals, including court cases, rulings, and guidance issued during the six months ending October 2025.
