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
Parag Patel delivers a presentation for the NJCPA Membership in Union County on Tuesday, November 18, 2025, titled “One Big Beautiful Bill”. The session focuses on the implications of the “One Big Beautiful Bill” legislation
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
