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
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
IRS Provides Second Extension for Taxpayers Affected by Terrorist Attacks in Israel
In Notice 2025-53, the IRS provided relief for individuals and businesses affected by terrorism in the State of Israel throughout 2024 and 2025. The new notice extends the relief granted to taxpayers in Israel, as well as the Gaza Strip and the West Bank, provided in Notice 2024-72. We previously discussed Notice 2024-72 in a... Continue Reading…More
IRS-ICE Information Sharing: Practical Tax and Immigration Considerations
In April, the IRS and ICE signed a Memorandum of Understanding (MOU) allowing the IRS to share taxpayer information, such as names, addresses, and tax data, with ICE for certain immigration-related criminal investigations and enforcement. The MOU poses significant issues for tax and immigration law practitioners, tests the boundaries of Internal Revenue Code Section 6103, and... Continue Reading…More
Threat to Harvard’s Tax Status Reaches All Nonprofits – A Bloomberg Daily Tax Report Column
Fox Rothschild partners Brian Bernhardt and Adam Young authored an article in Bloomberg’s Daily Tax Report examining both the ancillary threats to all nonprofits as a result of the Administration’s threat to revoke Harvard University’s tax-exempt status and what other nonprofits can do to prepare in advance for similar threats from the IRS. Read the... Continue Reading…More
False Claims Act Fallout from Pandemic Aid: What You Need to Know – A Fox Rothschild Webinar
Join Fox Rothschild White-Collar Criminal Defense & Regulatory Compliance partners Kevin Raphael, Brian Bernhardt, and Jonathan Wasser for a complimentary webinar addressing how to prepare for a potential Department of Justice investigation using the False Claims Act to enforce all types of fraud, including fraud related to the pandemic-era CARES Act stimulus packages. The panel will cover: For additional... Continue Reading…More
IRS Turns to New ‘John Doe’ Summonses in Continuing Quest to Combat Offshore Tax Evasion
In recent months the Internal Revenue Service (IRS) has started issuing “John Doe” summonses to overseas trust companies and their related entities and vendors to identify clients and obtain their contact information for the purpose of investigating the clients for evading federal taxes using offshore tax havens. This new approach has significant implications for taxpayers... Continue Reading…More
