Forbes contributors publish independent expert analyses and insights. Matthew Roberts is a tax attorney who covers tax litigation and fraud. Taxpayers with foreign assets often have international ...
On April 16, 2019, the Large Business and International (LB&I) Division of the Internal Revenue Service (IRS) announced three new compliance campaigns. The campaigns focus on: Transfer pricing for ...
In the recent U.S. Tax Court’s decision in Farhy v. Commissioner 160 T.C, No. 6 (April 3, 2023), the court ruled that the Internal Revenue Service lacks authority to assess and collect penalties from ...
The American Institute of CPAs is asking the Internal Revenue Service to provide relief from tax penalties to taxpayers who are required for the first time to file information returns related to ...
Donald Dewees is struggling to recoup a $120,000 penalty that the Canadian Revenue Department grabbed from him on behalf of our Internal Revenue Service. He had a setback last week with an unfavorable ...
The recent Tax Court decision in Farhy demonstrates that clever and novel arguments can carry the day in complex tax litigation matters. In that case, the taxpayer stipulated that he: (1) had Form ...
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