On December 22, 2025, the Internal Revenue Service announced a 90-day public comment period on a proposed revised Voluntary Disclosure Practice (“VDP”). The VDP is a compliance program designed for taxpayers who have willfully failed
The National Taxpayer Advocate recommends a law change to eliminate duplication. For tax professionals navigating the complexities of international tax law, few requirements are as redundant and potentially treacherous as the double reporting of foreign
For tax professionals representing clients in the medical field, the recent conviction of Dr. Pankaj Merchia serves as a reminder of the IRS’s reach. Last month, on January 27, 2026, a federal jury convicted the
Despite major budget cuts and layoffs, the Internal Revenue Service Criminal Investigation (IRS-CI) division continues to demonstrate its proficiency in untangling complex “off-the-books” financial arrangements. A recent case out of Massachusetts involving John Michael Sacco,
Can a taxpayer’s good-faith reliance on tax preparation software serve as a defense against IRS penalties? The U.S. District Court for the Northern District of California recently addressed this issue in Huang v. United States.
In December 2025, the IRS announced a 90-day comment period inviting input on proposed revisions to its under-utilized Voluntary Disclosure Practice (VDP). The VDP allows non-compliant taxpayers to come forward, disclose their noncompliance, and resolve
On January 7, 2026, the United States Court of Appeals for the Second Circuit issued its opinion in United States v. Reyes, holding that “willfulness” for purposes of civil FBAR penalties encompasses reckless conduct. For
The passage of the OBBBA has fundamentally reshaped the federal tax environment, moving many previously temporary incentives into the permanent fabric of the tax code. Here are some critical tips for advising business clients in
For tax practitioners, few issues in the international tax matters carry as much penalty risk as the reporting of foreign trust transactions and large foreign gifts. Under Internal Revenue Code (IRC) § 6039F, U.S. persons
Earlier this month, the Internal Revenue Service (IRS) has reportedly initiated a deployment of Salesforce’s AI platform, Agentforce, across key controversy and compliance divisions—including the Office of Chief Counsel, the Office of Appeals, and the
The federal indictment of Lorena Padilla of Villa Park, California, and her co-defendants is not merely a case of employment tax delinquency. It is a definitive example of how the government targets sophisticated schemes involving
Parag P. Patel, Esq. delivered a presentation today via a live webcast titled “Latest Federal Tax Controversy Update.” The session reviewed a discussion of the One Big Beautiful Bill Act (OBBB Act). (NJCPA). Additional highlights
