The Trust Fund Recovery Penalty (TFRP), authorized under Internal Revenue Code (I.R.C.) § 6672, remains one of the IRS’s most potent collection tools, allowing the IRS to hold individuals personally liable for an employer’s failure
The landscape of digital asset taxation continues to evolve, but the core principle established by the Internal Revenue Service (IRS) remains firm: cryptocurrency is treated as property, not currency, for Federal income tax purposes. This
In a long-awaited change that will bring relief to tax professionals, the Internal Revenue Service (IRS) has confirmed the elimination of the Acknowledgement of the Facts (AOF) Information Document Request (IDR). This procedural shift, detailed
The Internal Revenue Service (IRS) Independent Office of Appeals has initiated a significant two-year pilot program for Post Appeals Mediation (PAM), signaling a commitment to Alternative Dispute Resolution (ADR) and offering tax professionals new strategic
The IRS’s Inflexible Stance Discourages Good Faith Compliance The requirement for U.S. persons to report large foreign gifts via Form 3520 is well-known, as is the steep penalty for failure to file: the greater of
Parag Patel Esq. was the featured speaker at the National Association of Enrolled Agents (NAEA) Seminar “2025 Mid-Year Update” last month to over 500 tax professionals. Seminar description is below: “2025 Mid-Year Update” The informative
The global financial landscape is constantly shifting, presenting U.S. taxpayers and their professional advisors with a complex web of compliance challenges. For those managing clients with foreign assets, the obligations are particularly stringent, with potential
Despite staffing cuts, the Department of Justice (DOJ) continues to demonstrate its aggressive stance on employment tax evasion, with several significant prosecutions and sentencings announced in the past two months. For tax professionals, these cases
A recent case serves as a clear illustration of the serious consequences that can result from tax and financial non-compliance, particularly for high-net-worth individuals with foreign assets. The case, which involved a combination of tax
For tax professionals, successfully navigating the IRS appeals process is a critical skill that can profoundly impact a client’s outcome. It requires a deep understanding of not only tax law but also the procedural and
The operational landscape of the IRS has shifted dramatically in recent months, with a significant reduction in its workforce. This change, driven by broader government-wide initiatives, presents a new set of challenges for tax professionals.
The IRS Independent Office of Appeals, often seen as a crucial last stop for resolving tax disputes before litigation, is taking a significant step toward greater transparency. A blog post by the National Taxpayer Advocate
