For tax professionals, securing the deceased spousal unused exclusion (DSUE) amount for a surviving spouse is a cornerstone of effective wealth preservation. This is particularly vital in light of recent statutory changes that have increased
Starting this year, the Internal Revenue Service is transitioning from the manual First Time Abate (FTA) framework to a computerized infrastructure under the newly introduced Automatic Exemption from Penalty (AEP) program. For tax advisors managing
As international asset transparency reaches an all-time high, the IRS has dramatically escalated its scrutiny of cross-border holdings. For tax professionals, keeping pace with the aggressive enforcement priorities of the Internal Revenue Service (IRS) is
In federal tax controversy practice, managing the divergence between the IRS’s public-facing administrative declarations (website, FAQs, etc.) and its internal operational guidelines requires careful technical analysis. This distinction has become critical following the action of
The intersection of civil tax compliance and criminal tax exposure is one of the most perilous environments a client can face. As the IRS continues to ramp up its enforcement capabilities and refine its data-matching
The enforcement of Foreign Bank and Financial Accounts (FBAR) reporting requirements remains one of the highest-stakes areas of tax controversy practice. The IRS continues to aggressively pursue maximum willful penalties against taxpayers with undisclosed foreign
The enforcement landscape surrounding the Paycheck Protection Program (PPP) has entered a highly aggressive enforcement phase. What began as an administrative process managed by the Small Business Administration (SBA) has transformed into a large enforcement
An accountant recently asked us how to depreciate a rental property that was inherited by a client. The question had a complex answer. When a client inherits a rental property, tax professionals face the critical
Five years after the Paycheck Protection Program closed, federal enforcement against New Jersey businesses is accelerating, not winding down. As 2022 statute extends the government’s window to pursue PPP fraud to ten years, the District
For tax professionals managing international compliance, few issues carry higher high-stakes risk than a late-filed or incomplete Form 3520, Annual Return To Report Transactions With Foreign Trusts and Receipt of Certain Foreign Gifts. Historically, the
The ongoing litigation over the Internal Revenue Service’s administrative authority to assess international information-return penalties has entered a new phase. For the past few years, the tax community has closely monitored structural challenges to the
The U.S. Court of Federal Claims recently issued a landmark ruling in Kwong v. United States, 179 Fed. Cl. 382 (2025), that profoundly alters the landscape of Internal Revenue Service (IRS) compliance enforcement for the
