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Mitigating IRS Cryptocurrency Enforcement Risk in 2021

The high-stakes game of chicken regarding the IRS's enforcement of tax violations involving cryptocurrency holders is poised to move to the next level in 2021, K&F Director of Investigations Don Fort and Partner Lawrence Sannicandro explain in a recent Law360 article. After several years of

The Impact of the IRS’s Clarification of the DIIRSP

Recent clarifications to the Delinquent International Information Return Submission Procedures (“DIIRSP”) remind taxpayers and their advisors of the need to understand the standards, case law, and administrative guidance that apply to requests to have late-filing penalties abated on the ground of reasonable cause. In June