Tax Controversy & Financial Crimes Report Blog
Brian is a contributing author on this blog, which reports on the latest developments in all aspects of tax controversy and financial crimes. He writes about criminal tax; domestic and international compliance issues, and civil tax matters before the Internal Revenue Service. He also writes about audits, appeals, collection matters and tax litigation in the U.S. Tax Court, U.S. Court of Federal Claims, U.S. District Courts and U.S. Appellate Courts.
Recent Blog Posts
Taxpayer Assistance and Service Act Title VIII: Hostages
This is the eighth in a series of ten client alerts summarizing the key provisions of the Taxpayer Assistance and Service Act (the “TAS Act”), a bipartisan legislative package introduced on February 26, 2026, by Senators Crapo and Wyden to improve service and administration at the Internal Revenue Service (“IRS”). This alert addresses Title VIII... Continue Reading…More
Taxpayer Assistance and Service Act Title VII: Whistleblowers
This is the seventh in a series of ten client alerts summarizing the key provisions of the Taxpayer Assistance and Service Act (the “TAS Act”), a bipartisan legislative package introduced on February 26, 2026, by Senators Crapo and Wyden to improve service and administration at the Internal Revenue Service (“IRS”). This alert addresses Title VII... Continue Reading…More
Taxpayer Assistance and Service Act Title VI: IRS Independent Office of Appeals
This is the sixth in a series of ten client alerts summarizing the key provisions of the Taxpayer Assistance and Service Act (the “TAS Act”), a bipartisan legislative package introduced on February 26, 2026, by Senators Crapo and Wyden to improve service and administration at the Internal Revenue Service (“IRS”). This alert addresses Title VI... Continue Reading…More
Taxpayer Assistance and Service Act Title V: Tax Return Preparers
This article is the fifth in a series analyzing the proposed Taxpayer Assistance and Service Act (the “TAS Act”), bipartisan legislation introduced by Senators Crapo and Wyden to improve service and administration at the Internal Revenue Service (“IRS”). Our prior entries in the series are Title I (Tax Administration), Title II (American Citizens Abroad), Title... Continue Reading…More
Taxpayer Assistance and Service Act Title IV: Office of the Taxpayer Advocate
This is the fourth in a series of ten client alerts summarizing the key provisions of the Taxpayer Assistance and Service Act (the “TAS Act”), a bipartisan legislative package introduced on February 26, 2026, by Senators Crapo and Wyden to improve service and administration at the Internal Revenue Service (“IRS”). This alert addresses Title IV... Continue Reading…More
The Taxpayer Assistance and Service Act: Title III: Judicial Review
This article is the third in a series analyzing the proposed Taxpayer Assistance and Service Act (the “TAS Act”), bipartisan legislation introduced by Senators Crapo and Wyden to improve service and administration at the Internal Revenue Service (“IRS”). Our introduction to the series is here, our discussion of Title I is here, and our discussion... Continue Reading…More
The Taxpayer Assistance and Service Act: Title II: American Citizens Abroad
This article is the second in a series analyzing the proposed Taxpayer Assistance and Service Act (the “TAS Act”), bipartisan legislation introduced by Senators Crapo and Wyden to improve service and administration at the Internal Revenue Service (“IRS”). Our introduction to the series is here, and our discussion of Title I is here. This article... Continue Reading…More
Taxpayer Assistance and Service Act Title I: Tax Administration and Customer Service
Taxpayer Assistance and Service Act
Title 1: Tax Administration and Customer Service
By Meeren Amin, Brian C. Bernhardt, Kristy Caron, Matthew D. Lee, and Jonathan M. Wasser This article is the first in a series of articles analyzing the Taxpayer Assistance and Service Act (the "TAS Act"), bipartisan legislation introduced by Senators Crapo and Wyden to improve service and administration at the Internal Revenue Service (“IRS”). Our introduction to the series can be found [HERE]. This article examines the…More
Senators Introduce Bipartisan Legislation to Significantly Improve Federal Tax Administration and Procedure
On February 26, 2026, Senate Finance Committee Chairman Mike Crapo (R-Idaho) and Ranking Member Ron Wyden (D-Oregon) introduced the Taxpayer Assistance and Service Act, a bipartisan legislative package proposing significant reforms to Internal Revenue Service procedures and administration. The bill includes proposals recommended by the National Taxpayer Advocate along with other provisions designed to improve... Continue Reading…More
IRS Has Funds to Continue Operations for Five Business Days After Potential Midnight Government Shutdown
Despite the apparent forthcoming government shutdown at midnight tonight, the IRS is prepared to briefly continue its operations according to its “lapsed appropriations” plan. The plan, released yesterday, September 29, 2025, provides that funding from the Inflation Reduction Act will enable IRS employees to continue working for 5 business days following a government shutdown, through... Continue Reading…More
