Tax News and Developments September 2024 In brief Many litigants argue that FBAR penalties, which can exceed the value of the unreported foreign accounts, violate the excessive fines clause of the Eighth Amendment. Courts have routinely held that the Eighth Amendment does not apply in this situation. However, the Eleventh…
On 14 November 2023, the IRS issued the long-awaited proposed implementing regulations (REG-142338-07) under section 4966, added by the Pension Protection Act of 2006 (“Proposed Regulations”). The Proposed Regulations address many definitions related to donor advised funds, donors and donor advisors. The proposed regulations are intended to help taxpayers understand how the imposition of excise taxes on taxable distributions may apply to them.