Late on November 16th, the Senate Finance Committee voted to approve its iteration of the Tax Cuts and Jobs Act, passing the measure on a party-line 14-12 vote.  The full version can be found here.  Of particular interest to our readers here is one of the amendments that was added to this

The Tax Court’s opinion in Whistleblower 21276-13W v. Commissioner, 147 T.C. No. 4 (2016), was a clear and decisive win for whistleblowers.  The IRS has long been improperly trying to limit what should be included in “collected proceeds” and today’s opinion restores Congress’s intention that all proceeds that are collected be included in the

A congratulations and a thank you to Erica Brady, who yesterday spoke on behalf of The Ferraro Law Firm’s clients at the public hearing on the Proposed Treasury Regulations that outline how the IRS will interpret section 7623.  Erica joined other practitioners in pointing out that the Proposed Treasury Regulations should not be finalized in

Tax Analysts recently released a Chief Counsel Memorandum dated April 23, 2012, stating that the IRS cannot pay a section 7623(b) award on recoveries from the failure to report a foreign bank account commonly referred to as “FBAR” penalties.  While we believe Chief Counsel has this one wrong on the law and we will

Fiscal year 2011 was a big year for the IRS whistleblower program according to the IRS Whistleblower Office’s Fiscal Year 2011 Report to the Congress on the Use of Section 7623. Some of the highlights from the report are:

  • The number of submissions in fiscal year 2011 dropped by approximately 25 percent from the

Today the Treasury Department issued the finalized Treas. Reg. Section 301.7623-1(a) and (g) relating to the definition of “collected proceeds” for purposes of section 7623 tax whistleblower awards.  Although the language of the final whistleblower regulation was unchanged from the proposed regulation, the supplementary information to the final regulation reveals that the Treasury Department

Today The Ferraro Law Firm sent out a letter to IRS Commissioner Douglas Shulman (PDF) disputing an IRS policy that is negatively effecting most tax whistleblowers.  In July of 2009 Chief Counsel decided – without telling anyone – that the IRS will not pay any section 7623 whistleblower awards on “collected proceeds” resulting from whistleblower