Tax Controversy Sentinel Blog

Matt serves as the editor for the firm's Tax Controversy Sentinel blog, which reports on the latest developments in all aspects of tax controversy matters. These include criminal tax investigations and prosecutions, civil tax matters before the Internal Revenue Service including audits, appeals, and collection matters, as well as tax litigation. The blog also covers international tax compliance issues, including foreign bank account reporting (FBAR), the Foreign Account Tax Compliance Act (FATCA), and the IRS’s voluntary disclosure programs for both domestic and offshore issues.  Finally, Tax Controversy Sentinel addresses compliance issues arising under the Bank Secrecy Act, the USA Patriot Act, FATCA, the anti-money laundering laws and regulations, and economic sanctions regimes.

Recent Blog Posts

  • Tax Delinquents Beware: Your Passport Is Now Officially at Risk Individuals who owe more than $51,000 in back taxes are now at risk of losing their U.S. passports under a new law requiring the Internal Revenue Service to notify the State Department of taxpayers with “seriously delinquent tax debts.” This month the IRS will begin the process of certifying delinquent taxpayers to the State Department, which is required by law to deny passport applications (or renewal applications) filed by such individuals, and in some instances revoke existing passports. The IRS estimates that... More
  • Pennsylvania to Begin Issuing Penalty Assessments to Taxpayers Who Ignored 2017 Amnesty Program The Pennsylvania Department of Revenue this week will start mailing “non-participation penalty assessments” to delinquent taxpayers who failed to participate in the 2017 Tax Amnesty program, Revenue Secretary Dan Hassell announced yesterday. “Individuals and businesses that failed to take advantage of the program will be assessed a 5 percent penalty on their unpaid amnesty eligible delinquencies, as the law requires,” Hassell said. “The department is taking the appropriate steps to ensure that delinquent taxpayers are aware of their outstanding liabilities and... More
  • Coinbase Urges Bitcoin Users to Pay Their Taxes Coindesk is reporting that Coinbase — the largest U.S.-based Bitcoin exchange and the subject of a recently-concluded “John Doe” summons dispute with the Internal Revenue Service — is reminding its customers of their U.S. tax obligations with a new dashboard banner entitled “Please remember to pay your taxes.”  The banner then links to a “Taxes FAQ” page which states, in part, that “[w]e remind all our customers, both U.S. and international, that you have a responsibility to self-report and pay taxes... More
  • DOJ Reverses Cannabis Policy – What Does It Mean for the Industry? Our colleagues Joseph A. McNelis III and William Bogot have published a client alert addressing yesterday’s announcement by Attorney General Jeff Sessions that effectively ends the Obama Administration’s “hands off” approach to licensed cannabis operations in states where cannabis has been legalized for medicinal or recreational purposes. This announcement is important for all licensed cannabis businesses because the federal Controlled Substances Act classifies cannabis as a Schedule 1 substance, making it illegal to produce, sell, or possess cannabis. It also... More
  • IRS Announces That Tax Filing Season Will Open on January 29, 2018 The Internal Revenue Service announced today that the nation’s tax season will begin Monday, January 29, 2018 and reminded taxpayers claiming certain tax credits that refunds won’t be available before late February.  The IRS will begin accepting tax returns on January 29, with nearly 155 million individual tax returns expected to be filed in 2018.  The nation’s tax deadline will be April 17 this year – so taxpayers will have two additional days to file beyond April 15. Many software companies and tax... More
  • Federal Data Shows More Banks Are Serving Marijuana Businesses Over at the In the Weeds blog, we report on new federal data showing a steady increase in the number of depository institutions that actively bank U.S. marijuana businesses. As of September 30, 2017, a total of 400 banks and credit unions provided services to marijuana-related businesses, up from 334 as of December 31, 2016. FinCEN’s data is based upon Suspicious Activity Reports (SARs) required to be filed by financial institutions on activity involving a marijuana-related business.  FinCEN’s SAR filing... More
  • Treasury Inspector General Warns Taxpayers of IRS Impersonators As Tax Filing Season Approaches The Treasury Inspector General for Tax Administration (TIGTA) has reminded taxpayers to remain on “High Alert” during the coming tax filing season to avoid being scammed by criminals who impersonate Internal Revenue Service and Treasury employees in an effort to steal their money. In its announcement, TIGTA noted significant progress in the investigation and prosecution of the perpetrators of the scam, which has robbed U.S. taxpayers of more than $61 million since it began in 2013.  In total, TIGTA investigations have... More
  • New Tax Bill Means Changes for Employers: What You Need To Know Our colleague Tiana R. Seymore has authored a client alert addressing several provisions in the Tax Cuts and Jobs Act which directly impact the workplace, including one that gives some employers a credit for providing paid family and medical leave if they meet specific requirements and another that eliminates certain tax deductions in sexual harassment and sexual abuse cases.  You can read Tiana’s alert here. For more up-to-date coverage from Tax Controversy Sentinel, please subscribe by clicking here.... More
  • Changes to Estate and Gift Taxes in the New Tax Law Our colleague Debra T. Hirsch has authored a client alert addressing estate and gift tax planning issues impacted by the Tax Cuts and Jobs Act, which took effect yesterday.  You can read Debra’s alert here. For more up-to-date coverage from Tax Controversy Sentinel, please subscribe by clicking here.... More
  • IRS Issues Guidance Regarding Deductibility of Prepaid Real Property Taxes The Internal Revenue Service advised tax professionals and taxpayers today that pre-paying 2018 state and local real property taxes in 2017 may be tax deductible under certain circumstances. The IRS has received a number of questions from the tax community concerning the deductibility of prepaid real property taxes. In general, whether a taxpayer is allowed a deduction for the prepayment of state or local real property taxes in 2017 depends on whether the taxpayer makes the payment in 2017 and the real property... More