On March 4, 2026, Judge Richard K. Eaton of the U.S. Court of International Trade issued a three-page order in Atmus Filtration, Inc. v. United States that carries consequences far beyond the single plaintiff in that case. What the Order Says Judge Eaton directed U.S. Customs and Border Protection to do two things immediately: Liquidate…
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Taxpayers Should Be Prepared to Still File While CTA Beneficial Ownership Reporting Requirements are on Hold
Taxpayers are no longer required to report beneficial ownership information (“BOI”) to the U.S. Financial Crimes Enforcement Network (“FinCEN”). At least, for now. In a January 2, 2025, post on its webpage following a merits panel in the Fifth Circuit’s decision to uphold the universal injunction issued by the U.S. District Court for the Eastern…
Farhy Lives: Tax Court Declines to Follow the Farhy D.C. Circuit Ruling in Mukhi Case
For taxpayers who have received penalties for failure to file, or late filing of foreign information reporting requirements (e.g., Forms 5471, 5472, 8858 or 8865), recent decision out of the U.S. Tax Court bears great significance. On April 3, 2023, the U.S. Tax Court issued a ruling in Farhy v. Commissioner, stating that the Internal Revenue…
TWAG Attorneys Announce $14.3 Million in Tax Whistleblower Awards
On October 1st, the law firms of Kohn, Kohn & Colapinto and Zerbe, Miller, Fingeret, Frank & Jadav, working together at the Tax Whistleblower Attorney Group (TWAG), announced that two tax whistleblower awards totaling over $14.3 million were paid to their clients by the Internal Revenue Service (IRS). The awards reflect over $56 million in…
ZMF Victory for Micro-Captive
ZMF was featured in the May 2024 publication of Captive Insurance Times regarding the firm’s win in Ankner v. United States. The first taxpayer victory of its kind… “
