March 10, 2022
The Internal Revenue Service (“IRS”) has increased civil enforcement of international reporting requirements in recent years. In this article, we discuss the international reporting requirements and forms required to file.
The Art Industry Must Prepare for Congressional Increasing its Regulation of Money Laundering in the Art Market
November 24, 2021
In efforts to increase its regulations on the art industry, Congress has expanded the scope for financial institutions to regulate and scrutinize art-related transactions. Specifically, the Financial Crimes Enforcement Network of the United States Department of Treasury (“FINCEN”), earlier this year, issued formal notice to financial institutions of efforts related to trade in antiquities and art.
The United States Code of Federal Regulations Specificity Requirement with Respects to Internal Revenue Service Refund Claims
November 24, 2021
While taxpayers may be familiar with their ability to claim a refund in instances they have overpaid towards their tax liability, taxpayers must understand that they need to give the Internal Revenue Service a fair opportunity to administratively determine whether it should grant a refund.
June 18, 2021
As a taxpayer, you have the right to receive a refund from the IRS when there is an overpayment on your federal tax obligations. Even though this concept is quite simple, there are many procedural components that taxpayers must abide by to not compromise their ability to receive the funds to which they are entitled. The procedural requirements taxpayers must comply with are quite complex.
November 6, 2020
Section 6751(b)(1) provides that accuracy related penalties imposed by the IRS must have written approval from the immediate supervisor of the IRS employee making the “initial determination” to impose that penalty. But what exactly constitutes the initial determination? Is the initial determination made when the IRS internally decides the assessment of a penalty is appropriate?
- September 29, 2022 American Bar Association’s Tax Section’s Fall 2022 Tax Meeting
- September 29, 2022 California Tax Agencies Unlocked
- June 29, 2022 7th Annual USD School of Law – RJS LAW Tax Controversy Institute
- June 8, 2022 Jonathan T. Amitrano Selected As A 2022 Southern California Super Lawyers Rising Star
- May 20, 2022 A Win for Taxpayers: The United States Supreme Court Rules in Favor of Equitable Tolling with Respect to Non-Jurisdictional Deadlines