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ROBERT HORWITZ Weighs in and Quoted in Tax Notes on the Scope of the Supreme Court’s Recent Decision in CIC and the Potential Impact on International Information Reporting Penalties and Proposals for More Expansive Information Reporting

The Biden administration’s vision for increased information reporting, depending on implementation specifics, may have a new obstacle to contend with: the Supreme Court’s recent decision shortening the reach of the Anti-Injunction Act (AIA).

In its decision, the Supreme Court gave as one reason why the AIA did not apply was that there were several steps between a reporting rule and an assessment.

“Robert Horwitz of Hochman Salkin Toscher Perez PC also noted that if the IRS received a Form 1099 with an interest or dividend income reporting discrepancy, it would not automatically make an assessment on the taxpayer, but rather would inform the taxpayer and ask for an explanation.”

Robert S. Horwitz is a Principal at Hochman Salkin Toscher Perez P.C., former Chair of the Taxation Section, California Lawyers’ Association, a Fellow of the American College of Tax Counsel, a former Assistant United States Attorney and a former Trial Attorney, United States Department of Justice Tax Division. He represents clients throughout the United States and elsewhere involving federal and state administrative civil tax disputes and tax litigation as well as defending criminal tax investigations and prosecutions. Additional information is available at https://www.taxlitigator.com.

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