IRS

In CF Headquarters Corporation v. Commissioner, 164 T.C. No. 5 (2025), the Tax Court ruled that a financial services firm must include in gross income state grant proceeds it received following the September 11, 2001, terrorist attacks. The taxpayer argued that the funds provided by New York State as part of an economic recovery program […]

Good news! The U.S. Tax Court made a decision that could help taxpayers like you. In the case, Mukhi v. Commissioner, the court said the IRS lacks the authority to decide on its own to give you a penalty if you fail to report ownership of a foreign company. This decision conflicts with a previous […]

In Mukhi v. Commissioner, 163 T.C. No. 8 (2024), the U.S. Tax Court reaffirmed its earlier decision that the IRS lacks statutory authority to assess penalties under Internal Revenue Code §6038(b)(1) for failing to report ownership in foreign corporations. This ruling contrasts with a D.C. Circuit decision in another case, creating a divide in the […]

Update: As of November 21, 2019, various news sources are reporting that Former Mayor Pugh has pleaded guilty to four of the 11 charges in an executed plea deal. According to these reports, she pleaded guilty to at least one charge of tax evasion. Earlier this year, we reported the first public display of federal […]

Eli S. Noff, Esq., Partner By now, most Americans with assets abroad understand that the Internal Revenue Service (IRS) expects them to disclose these assets-or risk subjecting themselves to serious penalties for failure to comply. Recently, the IRS has provided significant and welcome relief from reporting requirements for a particular category of assets that were […]

Eli S. Noff, Esq., Partner EXECUTIVE SUMMARY The doctrine of collateral estoppel does not bar the IRS’s pursuit of civil tax liability, even where the same liability was previously resolved in a criminal proceeding. Taxpayers should remember that, depending on the circumstances, the Internal Revenue Service (IRS) may successfully pursue and recoup both civil deficiencies […]

The use of offshore accounts is a point of contention in the media these days. The release of the Paradise Papers and Panama Papers arguably aimed to bring down the reputation of those who used these accounts, but the information may have led to an unforeseen result. Instead of just leading to negative press, the […]

Glen E. Frost, Managing PartnerKaitlyn Loughner, Esq. On January 3, 2013, Switzerland’s oldest bank, Wegelin & Co. (“Wegelin”), pled guilty to assisting U.S. taxpayers in hiding more than $1.2 billion in assets from the Internal Revenue Service (“IRS”). Wegelin is the first foreign bank to plead guilty to U.S. tax evasion charges. In 2009, United […]

On May 5th Glen E. Frost wrote a letter, on behalf of the American Citizens Abroad, to IRS Commissioner John Koskinen in regards to private collection firms based in the United States collecting debts of U.S. taxpayers with foreign addresses. The ACA stands behind the belief that U.S. citizens living overseas should not be subject […]

People with unreported foreign assets on tax returns may benefit from the Offshore Voluntary Disclosure Program or the Streamlined process. U.S. persons who own property or other assets in countries outside the United States may do so in part for potential tax advantages. However, taxpayers may still need to report foreign assets on domestic income […]