In Tax Tip 2025-32, the IRS reminded U.S. citizens and resident aliens living abroad, including dual citizens, that they must have filed their 2024 federal income tax return and pay any tax due by Monday, June 16, 2025. This automatic two-month extension from the April 15 deadline applied to taxpayers whose principal place of business […]

In Garcia v. Comm., 164 T.C. No. 8 (2025), the Tax Court denied the IRS’s motion for summary judgment in a passport revocation case, ruling that unresolved factual issues prevented a determination that a taxpayer’s liabilities were “legally enforceable” under §7345. Alberto Garcia, Jr. challenged the IRS’s 2022 certification of his tax debts as “seriously […]

On April 7, 2025, the IRS and Immigration and Customs Enforcement (ICE) signed a memorandum of understanding (MOU) permitting ICE to request taxpayer information for immigration enforcement purposes. Under the agreement, ICE may seek data on individuals with deportation orders or under federal criminal investigation, invoking Internal Revenue Code §6103(i)(2). This marks a stark departure […]

The IRS announced that it has enhanced its Individual Online Account tool by adding access to key tax documents, including Form W-2, Wage and Tax Statement, and Form 1095-A, Health Insurance Marketplace Statement, for tax years 2023 and 2024. However, one key limitation remains: state tax information is not yet available on Form W-2s in […]

On March 26, 2025, the Financial Crimes Enforcement Network (FinCEN) published an interim final rule in the Federal Register that significantly narrows the scope of the Beneficial Ownership Information (BOI) reporting requirements under the Corporate Transparency Act (CTA). Most notably, domestic entities are no longer required to file BOI reports. The definition of a “reporting […]

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 […]

The IRS recently announced important changes to tax brackets, standard deductions, and retirement contribution limits for 2025. These adjustments, driven by inflation, impact your tax planning and savings strategies. Whether you’re proactively optimizing your strategy or already facing an IRS challenge, our tax attorneys can help. We focus on resolving IRS tax controversies and ensuring […]

Retirement accounts can be an integral part of wealth accumulation and estate planning. In this blog series, we consider the issues in Australian superannuation (retirement) accounts. Many Australians live in the US on E-3, O-1, and EB-2 visas, or as U.S. green card holders, or citizens. These U.S.-based Australians, have likely, accumulated retirement benefits in […]