On April 16, 2019, the Large Business and International (LB&I) Division of the Internal Revenue Service (IRS) announced three new compliance campaigns. The campaigns focus on: Transfer pricing for ...

The recent Tax Court decision in Farhy demonstrates that clever and novel arguments can carry the day in complex tax litigation matters. In that case, the taxpayer stipulated that he: (1) had Form ...

Forbes contributors publish independent expert analyses and insights. Matthew Roberts is a tax attorney who covers tax litigation and fraud.

Globalization has created extraordinary opportunities for U.S. taxpayers and multinational businesses. Yet, it has also placed U.S. accountants at the center of a fast-moving regulatory environment.

In the recent U.S. Tax Court’s decision in Farhy v. Commissioner 160 T.C, No. 6 (April 3, 2023), the court ruled that the Internal Revenue Service lacks authority to assess and collect penalties from ...