IRS Notice 2024-72, provides relief for individuals and businesses affected by terrorism in Israel.…

Introduction

For years, FBAR litigants have made the commonsense argument that large willful FBAR penalties, which can exceed the value of the unreported foreign accounts themselves, violate the excessive fines clause of the Eighth Amendment. Until recently, every court to consider this argument has held that the Eighth Amendment did not apply. On August 30,…

Last October, a District Court in Colorado turned the economic substance doctrine on its head. In Liberty Global, Inc. v. US, a District Court granted the Government’s motion for summary judgement and found that contrary to the plain language of IRC § 7701(o), there is no prerequisite requirement that the economic substance doctrine even be…

Summers are the ideal time for movies, baseball, long and winding road trips across the U.S. in search of the perfect family vacation or, just as important, a reasonable crypto tax reporting form. 

In response to the IRS’s April 2024 release of the draft Form 1099-DA (Digital Asset Proceeds from Broker Transactions), the crypto industry…

On July 23, 2024, the U.S. Court of Appeals for the D.C. Circuit reversed the U.S. Tax Court in holding that inventory gain recognized by a nonresident alien individual partner on the sale of her interest in a U.S. partnership was not taxable as U.S. source income. 

The taxpayer in Rawat is a Canadian citizen…

Last April, in Farhy v. Commissioner, the Tax Court held that the IRS did not actually have authority to assess penalties under IRC § 6038. The result was devastating for the IRS, as it meant it did not have authority to assess penalties for failure to file Forms 5472, 8865, 926, and 3520. In a…