Publications Archives

Recent Developments In FBAR Jurisprudence

By Usman Mohammad and Michael Gelb The CPA Journal, Tax Practice & Procedure Column December 2021 Issue Failing to report foreign bank accounts on a Report of Foreign Bank and Financial Accounts (FBAR) form can carry severe financial consequences. The civil penalty for non-willful violations

The IRS’s Big Plans For Big Data

By Christopher M. Ferguson CPA Journal August/September 2021 Faced with shrinking budgets and resources, for more than a decade the IRS has been forced to do more with less. It has responded by turning to big data analytics. In recent years, the IRS has amassed

John Doe Summonses, Cryptocurrency, and the Taxpayer First Act

By Megan L. Brackney and Jas Singh Tax Notes State October 2021 Abstract: In this article, Brackney and Singh explore the effect of the Taxpayer First Act’s procedural requirement that John Doe summonses be “narrowly tailored to information that pertains to the failure (or potential

Calling For Backup: When Do You (Or Your Clients) Need To Bring In Counsel?

By Caroline D. Ciraolo EA Journal September/October 2021, Vol.39 No.5 Tax controversy practitioners include various professionals with diverse experience and expertise. From tax return preparers to certified public accountants (CPAs) and enrolled agents (EAs) to tax attorneys, a client has many options in seeking advice

Increasing Diversity In Tax Law

By Destiny Reese The Federal Lawyer September/October 2021 Unfortunately, few undergraduate and law school students aspire to become tax attorneys. This is primarily because tax law is often mistaken to be solely concerned with preparing tax returns for wealthy people or working for the Internal

A Primer On Establishing A Trust And Its Taxation

By Sidney Kess and Edward Mendlowitz Practical Tax Strategies June 2021 Trusts are an effective mechanism to provide for transfers of assets, protect assets from eventual or potential creditors, enable assets to be used in situations where the person establishing the trust is not able

Biden Promised To Bring In $700 Billion By Beefing Up The IRS And Going After Tax Cheats. 2 Former IRS Commissioners Explain How He Can Actually Do It.

By John D. (Don) Fort and Eric Hylton Business Insider July 3, 2021 President Joe Biden is finally making a crackdown on tax fraud a priority, but whether he can deliver on his lofty promises to strengthen the Internal Revenue Service is still very much

OPR’s Star Chamber: Felons And The IRS’s Opaque Sanctions Process

By Megan L. Brackney and Daniel Q. Flesch Tax Notes Federal; Tax Notes State July 2021 Abstract: In this article, Brackney and Flesch examine the lack of transparency in the IRS Office of Professional Responsibility’s sanctions process and explore recently released administrative law judge and

What To Do When You’re Under The Government’s Microscope

By Claude M. Millman and Daniel Q. Flesch New York Nonprofit Media July 2021 Virtually no non-profit executive welcomes an audit or investigation with open arms. If you’ve dedicated your life to bettering the world by fighting for a social cause, you might react to

Penalties – The IRS’s New Practice Of Assessing Late-Filing Penalties On Timely Filed Substitute Forms 3520-A

By Caroline Rule and Jas Singh The Journal of Tax Practice & Procedure Summer 2021 Issue The IRS has begun systematically imposing late-filing penalties on substitute Forms 3520-A even when they have been filed on time. This new mistaken practice forces a taxpayer who does