Feigenbaum Law

IRS

Appeal

Tax Disputes & Litigation

Mark Feigenbaum Files Appeal to the U.S. Supreme Court in High-Stakes Cross-Border Tax Issue

Our offices have recently filed a Writ of Certiorari, a request to appeal to the United States Supreme Court, asking that court to review lower court level decisions made with respect to a client who had significant IRS penalties levied against him. What Happened? Our client, an American who has lived in Canada since the 1970’s, had not filed any income tax statements in the U.S. since his relocation north of the border. The man… Read More

Appeal

Corporate Tax Planning

The Taxpayer First Act: IRS Reform Legislation Passed by Senate

After initially being introduced more than a year ago, the Taxpayer First Act has been passed by the House and Senate. The legislation includes a variety of provisions intended to modernize the Internal Revenue Service across a wide range of critical areas including information technology, identity theft protection, and customer service. While it remains to be seen what happens next, it is widely believed that President Trump will sign the bill… Read More

Tax fraud

Personal Tax Planning

Parents Involved in Recent College Admissions Bribery Scandal May be Facing Tax Fraud Charges

According to Bloomberg News, parents embroiled in the recent “Varsity Blues” college admissions scandal may now be facing serious tax consequences in addition to criminal charges and potential prison time. The Varsity Blues Scandal- Some Background In a federal indictment spanning multiple jurisdictions, approximately 50 individuals, mostly wealthy parents, were recently charged with conspiracy to commit mail fraud and honest services mail fraud, after it was discovered that they had bribed multiple universities to admit… Read More

IRS Commissioner

Corporate Tax Planning

New IRS Commissioner Outlines Goals for his Term

Earlier this fall, the Senate confirmed President Trump’s pick to head the Internal Revenue Service (IRS). Charles Rettig previously practiced tax law in California for more than 36 years. During that time, he often represented taxpayers in disputes with the IRS and was a member of the IRS Advisory Council (IRSAC) for three years beginning in 2008, and served as IRSAC’s chair from 2010 to 2011. Rettig was confirmed as Commissioner of the… Read More

Private debt collection

Corporate Tax Planning

Inspector General Identifies Issues with IRS’ Private Debt Collection Program

Earlier this year, the Internal Revenue Service (IRS) launched a new private debt collection program, and outsourced debt collection over certain accounts to four private contractors. More than 500,000 accounts consisting of more than $4.1 billion in outstanding debts were part of the program. Recently, the Treasury Inspector General for Tax Administration (TIGTA) identified a number of issues with the program. Program Introduced by Congress The program was authorized under Section 32102 of… Read More

Voluntary disclosure

Corporate Tax Planning

The End of IRS’ Voluntary Disclosure Program is Imminent

Earlier this year, the Internal Revenue Service (IRS) announced that it would begin to ramp down the 2014 Offshore Voluntary Disclosure Program (OVDP) and the program would be fully closed by September 28, 2018. The Offshore Voluntary Disclosure Program The OVDP initially launched in 2009, with a second program offered in 2011, and then 2012. The current program launched in 2014. These voluntary disclosure programs have enabled American taxpayers… Read More

Appeal

Tax Disputes & Litigation

Thousands of Americans May Be Denied a Passport Due to Unpaid Taxes

The IRS has begun to enforce a law passed by Congress in late 2015, which permits the State Department to revoke or deny passports to Americans who have significant tax arrears. More than 360,000 Americans who owe taxes are set to be affected. The Law Where an American has significantly delinquent tax debt (more than $51,000), IRC § 7345 authorizes the IRS to certify that debt to the State Department for action. The State Department… Read More

Tax fraud

Corporate Tax Planning

IRS Announces $291 Million Plan for Implementing Tax Reform

Earlier this year, Congress earmarked $320 million of the Internal Revenue Service’s (IRS) total $11.4 billion budget for implementing the reforms resulting from one of the largest overhauls of the U.S. tax code in many years. A recently disclosed document reveals that the IRS will spend almost $300 million to carry out necessary changes. Some Context In March 2018, Treasury Secretary Steve Mnuchin had… Read More

Appeal

Corporate Tax Planning

IRS Notably Silent on New Tax Regulations

We’ve previously discussed one of the largest overhauls of the U.S. tax code, which are set to have an impact on Americans and Canadians living on both sides of the border. Since then, both the Internal Revenue Service and the Treasury Department have been notably quiet about regulations that the government plans to issue stemming from the legislative changes. The reluctance to provide information comes at a time when tax lawyers and… Read More

Hurricane Harvey

Personal Tax Planning

IRS Announces Policy Change to Access to Retirement Plan Funds for Hurricane Harvey Victims

With weather-related catastrophes ongoing in the United States, the IRS recently announced a loosening of the rules that normally restrict a retirement plan participant’s access to their retirement funds for residents in areas of Texas affected by Hurricane Harvey. In Announcement 2017-11 (the Announcement), the IRS outlined a relief plan for taxpayers who have been adversely affected by Hurricane Harvey, and who have retirement assets in qualified employer plans that they would… Read More