The Internal Revenue Code (IRC) imposes penalties on understatements of tax as a way to encourage voluntary compliance and deter noncompliant behavior. Generally, the revenue…
TPP | Reasonable Cause for International Information Return Penalties
What Is the Standard?
The Internal Revenue Code (IRC) requires the filing of a number of different information returns with respect to foreign entities or transactions. These “international information…
The “trust fund recovery penalty” can impose sizeable liabilities on officers and other employees of financially struggling or failed companies that fail to pay withholding…
The ‘Reasonable Cause and Good Faith’ Defense to Penalties
Lessons from Hobby Loss Cases
The gold standard for a “reasonable cause and good faith” defense to a tax penalty is reliance on advice from a professional tax advisor who…