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Stephen Josey and Quentin Manuel examine how the IRS enforces civil tax fraud penalties within the federal tax system, offering practitioners key insights into the legal standards, evidentiary burdens, and practical consequences involved. They explain how civil fraud differs from negligence and criminal tax fraud, highlight the IRS’s reliance on circumstantial evidence and badges of fraud, and outline the significant financial and legal risks taxpayers face when fraud is found. They also address defenses available to taxpayers and emphasize the importance of distinguishing between intentional misconduct and good-faith mistakes in today’s enforcement environment.
Published by Taxes The Tax Magazine®
As the Trump administration continues to roll out its sweeping tariff policy, the North American energy industry is working to address the effects of the President’s tariff strategy. The Trump administration intends to “unleash American energy,”1 in part by imposing tariffs designed to remedy what the administration views as unfair trade practices and increase U.S. domestic energy production. The currently imposed and threatened tariffs will inevitably impact the energy industry and its consumers. The particularly relevant tariffs can be defined in two broad categories: (1) sectoral tariffs, in this case, imposed under Section 232 of the Trade Expansion Act of 1962, and (2) the country-specific and “reciprocal tariffs” that the Trump administration has imposed under the International Emergency Economic Powers Act.
Published by RiEnergia, July 2025
On July 4, 2025, President Donald J. Trump signed the One Big Beautiful Bill Act (the “OBBBA”) into law. Congress passed the OBBBA through budget reconciliation, a special legislative process that allows Congress to advance certain tax, spending, and debt limit legislation with a simple majority vote in the Senate so long as the legislation does not increase the federal budget deficit outside a 10-year budget window.
V&E Tax Update
On July 4, 2025, President Trump signed the “One Big Beautiful Bill Act” (H.R. 1 119th Congress) (“OBBBA”) into law.
V&E Renewable Energy Update
In the afternoon of June 16, 2025, the Senate Finance Committee (“SFC”) released its proposed legislative text of the tax title for the “One Big Beautiful Bill,” H.R. Con. Res. 14, 119th Cong. (2025) (the “Reconciliation Bill”).
V&E Renewable Energy Update
After an intense 21-hour House Rules Committee markup, early in the morning of May 22, 2025, the House passed H.R. Con. Res. 14, 119th Cong. (2025) (the “Reconciliation Bill”), which makes significant revisions to the Inflation Reduction Act (the “IRA”) provisions.
V&E Renewable Energy Update
Early this morning, the House Ways and Means Committee (the “Ways and Means Committee”) approved its recently proposed markup of H.R. Con. Res. 14, 119th Cong. (2025) (the “Reconciliation Bill”).
V&E Renewable Energy Update
The opening days of the 119th U.S. Congress have been marked with congressional action under the Congressional Review Act (CRA) to potentially invalidate regulations that were issued by the Internal Revenue Service (IRS) in the final days of the Biden administration.
V&E Tax Update
On March 14, 2025, President Trump signed legislation disapproving the Environmental Protection Agency’s regulation implementing the Inflation Reduction Act’s tax on methane emissions from the oil and gas sector.
V&E Environmental Update
For more than twenty years, the North American Free Trade Agreement (“NAFTA”), and later, the United States‑Mexico-Canada Agreement (“USMCA”), have facilitated cross-border trade and investment among the United States, Mexico, and Canada through the elimination of virtually all financial barriers to trade.
V&E Energy Update
Published by Energy Intelligence and Hart Energy, March 2025