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.
Qualifying taxpayers who failed to report foreign-source income and can prove their conduct was not "willful" could enjoy significantly reduced penalties.
This item discusses the PATH legislation’s immediate impact on certain federal penalty computations.
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.
IRS could impose penalty because the examiner had made an initial determination that the penalty applied.
Passports can be denied to any person whom the IRS certifies as having seriously delinquent tax debt.
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.
The guidance provides procedures to ensure consistency and efficiency in the IRS’s administration of the FBAR compliance program.
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.
The Erwin case is an important reminder that an accountant can be held liable for a client’s unpaid employment taxes.
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.
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.
This article examines recent developments in parallel civil and criminal investigations as they have been reinvented over the past decade.
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.
The Trade Preferences Extension Act of 2015 contains tax provisions in addition to the trade measures that were the focus of the bill.
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.
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.
The IRS will provide automatic penalty relief for taxpayers who, when they reconcile advance payments of the premium tax credit they received for 2014 to the amount of the credit they are entitled to on their income tax returns, find they owe additional tax.
The IRS issued final regulations under Sec. 6707, which imposes a large penalty on any material adviser who fails to file a return required under Sec. 6111(a) disclosing a reportable transaction or who files a false or incomplete return.