Practitioners are disturbed by a possible legal stance of the Justice Department in the latest dust-up over foreign bank account reporting, which would negate reliance on a professional as a defense to willful penalties. Tax Notes talked with two practitioners following filings of a joint pretrial statement and proposed jury instructions in Dadurian that seemingly […] Read More…

The IRS has recently provided interim guidance to clarify actions IRS Examiners musttake to analyze and document Currency Transaction Report (CTR) data during an audit.  The Guidance, which is effective immediately, will be incorporated into IRM 4.10.4, Examination of Returns, Examinations of Income. Prior to incorporation, IRM 4.10.4 provided very little guidance on when and how to […] Read More…

We are pleased to announce that Sandra R. Brown, along with Chair Ian Comisky, Fox Rothschild and Panelists Don Fort, Chief, Criminal Investigation IRS, Larry Campagna, Chamberlain Hrdlicka, and Caroline Ciraolo, Kostelanetz & Fink, will be speaking on “Cooperation or Compulsion: The Emerging U.S. Experience with Voluntary and Involuntary Disclosures of Foreign Transactions,” at the […] Read More…