According to Law360, the Third Circuit on May 14, 2019 upheld decades-old tax regulations tied to a $377 million dispute involving the affiliate of a commodities trader, ruling that the IRS wasn’t expected to foresee every possible impact of the rules when they were written. In a precedential ruling, a three-judge panel affirmed a U.S.…
Read more
IRS Review of Foreign Reporting Information Results in Another 50% FBAR Penalty Case
A real estate developer willfully failed to report an overseas bank account to the Internal Revenue Service and is responsible for $456,000 in penalties, a Texas federal court found on June 11,2019. Defendant Edward Flume is a U.S. citizen who has lived and worked in Mexico since 1990. A savvy businessman, Flume has successfully parlayed…
Read more
Few Accuracy-Related Penalties Are Proposed in LB&i Examinations and They Are Generally Not Sustained on Appeal!
The Internal Revenue Service tends to impose relatively few accuracy-related penalties during audits of large businesses, according to a new report. The report, from the Treasury Inspector General for Tax Administration, noted accuracy-related penalties are generally 20 percent of the underpayment of taxes due, and in certain cases, the penalty can be as high as…
Read more
Senate Passes IRS Reform Bill
The Senate passed the Taxpayer First Act (H.R. 3151) on Thursday, June 13 by a voice vote. The bill includes provisions to improve customer service, protect personal data, preserve tax-preparation services and curb private debt collectors. The measure now goes to the President who is expected to sign. On June 6, House Ways and Means Committee…
Read more
