The latest news on IRS Tax Whistleblowing
WSJ on Tax Whistleblower Lawyers
Paul Caron, TaxProf Blog, December 27, 2020
The Tax Prof blogs Wall Street Journal article regarding Scott A. Knott and Gregory S. Lynam, Tax Partners of The Ferraro Law Firm.
The Profitable Prospects of Snitching for the IRS
Laura Saunders, April 26, 2019
Tax Partner, Gregory S. Lynam, discusses the getting an award for providing information to the IRS and what it takes to get an award.
Whistleblowers Hope for an Ally at IRS
Henry Cutter, The Wall Street Journal, April 27, 2018
Scott A. Knott, Tax Partner at The Ferraro Law Firm, discusses the future of the IRS Whistleblower Office under the leadership of Charles Rettig, the nominee for IRS Commissioner.
Whistleblower Awards Total Payouts Fell Dramatically in 2017
Andrew Velarde, Tax Analysts, Tax Notes, January 8, 2018
Gregory S. Lynam, Scott A. Knott, and Erica L. Brady discuss some of the takeaways from the IRS Whistleblower Office’s FY 2017 Annual Report to Congress.
Collected Proceeds Don’t Limit Whistleblower Amounts in Dispute
Andrew Velarde, June 8, 2017
In another win for whistleblowers, the Tax Court held June 7 that the “amounts in dispute” threshold under section 7623 is not limited to the portion of “collected proceeds” attributable to whistleblower information. In Ian D. Smith v. Commissioner, No 25605-15W (June 7, 2017), the whistleblower alleged that a business was exchanging products or services […]
Legislation Aims to Improve Communication with Whistleblowers
Matthew R. Madara, Tax Analysts, Tax Notes, March 30, 2017
Practitioners praised bipartisan legislation introduced March 29 in the Senate intended to improve communication between the IRS and whistleblowers and provide them protection against workplace retaliation. The IRS Whistleblower Improvements Act of 2017, introduced by Senate Finance Committee member Chuck Grassley, R-Iowa, and committee ranking minority member Ron Wyden, D-Ore., seeks to improve communication by […]
New IRS Whistleblower Report Shows More Awards, Fewer Dollars
Andrew Velarde, Tax Analysts, Tax Notes Today, January 13, 2017
The latest annual report from the IRS Whistleblower Office shows a substantially higher number of awards paid in comparison to the previous year, along with a significantly lower total award amount. According to the Whistleblower Office’s fiscal 2016 report , released January 12, the office made 418 awards to whistleblowers in fiscal 2016 under section […]
Fines and Forfeitures Count as Whistleblower-Collected Proceeds
Andrew Velarde, Tax Analysts, Tax Notes Today, August 3, 2016
In an important win for whistleblowers, the Tax Court on August 3 determined that criminal fines and civil forfeitures are collected proceeds for purposes of whistleblower awards, refusing to narrow what it saw as the broad scope of the statutory language. “The phrase ‘collected proceeds’ is sweeping in scope and is not limited to amounts […]
Big Win for Whistleblowers as Pair Gets $17.8 Million
Richard Rubin and Laura Saunders, The Wall Street Journal, August 3, 2016
The U.S. Tax Court awarded $17.8 million to a pair of whistleblowers in a decision that significantly expands the scope of what can be claimed in such cases. The ruling for the first time allowed the whistleblowers to get a portion of criminal fines and civil forfeitures in addition to part of the taxes the […]
2015 Whistleblower Report Touts Big Year
Andrew Velarde, Tax Analysts, Tax Notes Today, February 22, 2016
Citing the growing number of awards it gave out in 2015, the IRS Whistleblower Office in its annual report released February 10 called 2015 “a big year,” but practitioners cautioned that the office still has work to do on improving its claims process. According to the report , 99 awards, including 19 payments under section […]
GAO Faults Whistleblower Program Over Timeliness, Communications
Andrew Velarde, Tax Analysts, Tax Notes Today, December 1, 2015
Timeliness and communication concerns may discourage whistleblowers from coming forward to the IRS with information, according to a Government Accountability Office report released publicly on November 30. The IRS Whistleblower Office’s “communication with stakeholders, including whistleblowers, is limited due to delayed annual reports to Congress, incomplete data, and limited program information for whistleblowers,” the report […]
Tax Court Orders Discovery Beyond Whistleblower Office File
Nathan J. Richman, Tax Notes Today, Tax Analysts, September 17, 2015
The Tax Court on September 16 granted discovery requested by three whistleblowers over IRS objections that the information requested is not in the Whistleblower Office’s case file. In Whistleblower One 10683-13W v. Commissioner, 145 T.C. No. 8 (2015) , the Tax Court ordered the IRS to respond to whistleblowers’ discovery requests despite the government’s claim […]
Martin and Whitlock to Switch as OPR and Whistleblower Heads
Nathan J. Richman, Tax Notes Today, Tax Analysts, July 24, 2015
Erica L. Brady of The Ferraro Law Firm wishes Director Stephen Whitlock well in his new post as Director of OPR and welcomes Acting Director Lee Martin as the new Director of the IRS Whistleblower Office.
Whistleblower Report Is Good News, Bad News Situation
Andrew Velarde, Tax Analysts, Tax Notes Today, July 8, 2015
Scott A. Knott and Erica L. Brady, of The Ferraro Law Firm, discuss the statistics published in the fiscal year 2014 Annual Whistleblower Office Report to Congress.
$1.2 Billion Secret Account Whistleblowers Are Award Eligible
Andrew Velarde and William R. Davis, Tax Analysts, Tax Notes Today, June 3, 2015
Gregory S. Lynam and Scott A. Knott, Tax Partners at The Ferraro Law Firm, discuss the recent U.S. Tax Court opinion holding that a whistleblower is not required to provide the information to the IRS Whistleblower Office before providing the information to an IRS operating division or another Federal agency to be award eligible.
Whistleblower Status Letters Seen as a Good Start but Not Enough
Andrew Velarde, Tax Analysts, Tax Notes Today, March 19, 2015
Scott A. Knott, Tax Partner at The Ferraro Law Firm, notes that the annual status letters are a good start, but believes that the IRS should be using section 6103(n) agreements to facilitate two-way communications with whistleblowers.
2014 Whistleblower Statistics Will Mirror Past Reports
Andrew Velarde, Tax Analysts, Tax Notes Today, March 9, 2015
Scott A. Knott, Tax Partner at The Ferraro Law Firm, led a panel discussion of the IRS Whistleblower Program at the Federal Bar Association Section of Taxation's 2015 Law Conference, where the yet-to-be-released 2014 Whistleblower Office Report to Congress was previewed, noting that he believes that the number of good submissions has remained steady over the years.
Chief Counsel Undermining Whistleblower Program, Grassley Says
Andrew Velarde, Tax Analysts, Tax Notes Today, February 13, 2015
Gregory A. Lynam and Scott A. Knott, Tax Partners at The Ferraro Law Firm, comment on the question Senator Grassley posed to Commissioner Koskinen regarding the administration of the IRS whistleblower program.
Whistleblower Counsel Praise Tax Court for Keeping Claim Open
Amy S. Elliott, Tax Analysts, Tax Notes Today, November 24, 2014
Scott A. Knott, Tax Partner at The Ferraro Law Firm, discusses the impact of the United States Tax Court's decision that the dollar limitations in section 7623(b)(5)(B) are not jurisdictional limitations.
ABA Meeting: Whistleblower Regs’ Tax Attribute Rule Is a ‘Double-Edged Sword’
Andrew Velarde, Tax Analysts, Tax Notes Today, September 22, 2014
Ferraro Law Firm partner Gregory S. Lynam spoke at the Administrative Practice session of the American Bar Association Section of Taxation meeting in Denver on a panel with IRS Whistleblower Office Director Stephen Whitlock, and commented on numerous aspects of the program including the effect of tax attributes on the computation of collected proceeds in whistleblower cases.
Practitioners Praise IRS’s Decision to Grow Whistleblower Office
Andrew Velarde, Tax Analysts, Tax Notes Today, September 18, 2014
Scott A. Knott, Tax Partner at The Ferraro Law Firm, discusses the effects of the decision by IRS Commissioner John Koskinen to expand the IRS Whistleblower Office.
IRS Provides Welcome Update to Whistleblower Program Goals
Andrew Velarde, Tax Analysts, Tax Notes Today, August 21, 2014
Erica L. Brady of The Ferraro Law Firm discusses the updated Field Directive from the Deputy Commissioner for Services and Enforcement.
4 Tips on Scoring Big For IRS Whistleblowers
Ama Sarfo, Law360, August 18, 2014
Scott Knott, Tax Partner at The Ferraro Law Firm, discusses ways to improve a whistleblower's chance of success when submitting a information to the IRS Whistleblower Office.
Tax Court’s Stance on Anonymous Whistleblowers Draws Praise
Matthew R. Madara, Tax Analysts, Tax Notes Today, May 22, 2014
Scott A. Knott, Tax Partner at The Ferraro Law Firm, discusses the three recent rulings regarding proceeding anonymously in the United States Tax Court and when the extraordinary step of sealing the record is appropriate.
IRS Pays Awards to Whistleblowers
Laura Saunders, Wall Street Journal, April 18, 2014
Gregory S. Lynam, Tax Partner with The Ferraro Law Firm, discusses the Annual IRS Whistleblower Report to Congress for fiscal year 2013 and the award paid to a client of The Ferraro Law Firm.
Whistleblower Award Processing Continues to Lag
Andrew Velarde, Tax Analysts, Tax Notes Today, April 7, 2014
Scott A. Knott, Tax Partner at The Ferraro Law Firm, discusses the IRS Whistleblower Office's Fiscal Year 2013 Annual Report to Congress and changes to the Form 211
The Perks of Being a Whistleblower
Lynnley Browning, Newsweek, January 30, 2014
Gregory S. Lynam, Tax Partner at The Ferraro Law Firm, discusses the IRS's whistleblower program and gives his unique perspective on some of the rewards and the risks of the program.
Whistleblower Case Lost as Precedent After IRS Denies Claim, Attorneys Say
Diane Freda, Daily Tax Report, April 23, 2013
Gregory S. Lynam, Tax Partner at The Ferraro Law Firm, discusses the change in importance of the Insinga case following the IRS's issuance of a denial letter.
IRS Formally Denies Whistleblower Award in Insinga Challenge
Jeremiah Coder, Tax Analysts, Tax Notes Today, April 19, 2013
Gregory Lynam, Tax Partner at The Ferraro Law Firm, discusses the issuance of a formal denial of the claim may have avoided an unfavorable precedent and what the next steps will likely be.
Appeal Expected in IRS Whistleblower Award Rejection
Ben DiPietro, Wall Street Journal Blogs, April 19, 2013
Scott Knott, Tax Partner at The Ferraro Law Firm, discusses the impact of the IRS issuing a formal denial of Mr. Insinga's whistleblower claims and how the Proposed Treasury Regulations has likely shaped the decision to deny his claim.
IRS Whistleblower Program Slammed by Tax Informants
Kevin Drawbaugh, Reuters, April 11, 2013
Erica Brady of The Ferraro Law Firm explains that the IRS needs to do a better job of showing that the IRS welcomes whistleblowers when finalizing the Treasury Regulations.
IRS Failure to Dialogue With Whistleblowers Creates Unwelcome Climate, Witnesses Say
Diane Freda, BNA Daily Tax Report, April 11, 2013
Erica Brady of The Ferraro Law Firm encourages the IRS to reconsider the language of the Proposed Treasury Regulations, particularly the language limiting "Proceeds Based On."
Speakers Detail Frustrations With IRS Whistleblower Regs
Jeremiah Coder, Tax Analysts, Tax Notes Today, April 11, 2013
Erica Brady of The Ferraro Law Firm addresses a government panel regarding concerns over four key areas of the Proposed Treasury Regulations.
Sequester Means Reduced Whistleblower Awards, IRS says
Jeremiah Coder, Tax Analysts, Tax Notes Today, March 5, 2013
Gregory S. Lynam and Scott A. Knott, Tax Partners at The Ferraro Law Firm, discuss why the IRS's position to reduce whistleblower award payments as part of the automatic sequester cuts is prohibited by the statutory language of section 7623(b).
IRS Highlights Large Awards To Whistleblowers In New Report To Congress; Concerns Remain
George L. Yaksick, Jr., CCH Standard Federal Tax Reports, February 21, 2013
Scott A. Knott, Tax Partner at The Ferraro Law Firm, discusses the effectiveness of the IRS Whistleblower Program and his expectation that collections will grow significantly over time.
Birkenfeld Award Boosts Payout Under IRS Whistleblower Law
Ben DiPetro, Wall Street Journal Blogs, February 14, 2013
Scott A. Knott, Tax Partner at The Ferraro Law Firm, discusses the effect the payments of large awards has had on the program and the tangible results the IRS can show for the Whistleblower Program.
IRS FY 2012 Whistleblower Report Shows Steady Submission of Claims
Diane Freda, BNA Daily Tax Report, February 14, 2013
Gregory S. Lynam, Tax Partner at The Ferraro Law Firm, explains the results that the IRS has to show for the IRS Whistleblower Program.
IRS Report on Whistleblower Awards Shows Slow Growth and Long Waits
Jeremiah Coder and Shamik Trivedi, Tax Analysts, Tax Notes Today, February 14, 2013
Gregory S. Lynam and Scott A. Knott, Tax Partners at The Ferraro Law Firm, discuss the highlights of the IRS Whistleblower Office's Fiscal Year 2012 Annual Report.
Proposed IRS Whistleblower Rules Could Undermine FATCA , Critics Argue
Ben DiPetro, Wall Street Journal Blogs, February 12, 2013
Scott A. Knott, Tax Partner at The Ferraro Law Firm, discusses the potential impact on whistleblowers if the Proposed Treasury Regulations are adopted as they are currently written.
Birkenfeld Award Enhances Credibility of IRS Whistleblower Program, Official Says
Michael Bologna, BNA Daily Tax Report, January 29, 2013
Gregory S. Lynam, Tax Partner at The Ferraro Law Firm, discussed the importance of the IRS paying large awards and keeping the whistleblower's information confidential while speaking on a panel with Director Stephen Whitlock, IRS Whistleblower Office, and Eli Dicker, Executive Director at Tax Executive Institute, at the American Bar Association, Section of Taxation's Mid-Year Meeting.
ABA Meeting: Whitlock Reaffirms IRS Support for Whistleblower Program
Jeremiah Coder, Tax Analysts, Tax Notes Today, January 28, 2013
Gregory S. Lynam, Tax Partner at The Ferraro Law Firm, discussed the key changes that are being made in the IRS Whistleblower program that will improve how claims are processed while on a panel with Director Stephen Whitlock, IRS Whistleblower Office, and Eli Dicker, Tax Executive Institute, at the American Bar Association, Section of Taxation's Mid-Year Meeting. Mr. Lynam specifically mentioned changes such as the payment of large awards, the promise of anonymity, and an administrative process for communicating information regarding denial of an award claim.
New IRS whistleblower rules may limit some rewards – lawyers
Patrick Temple-West, Thomson Reuters News & Insight, December 17, 2012
Scott Knott, Tax Partner at The Ferraro Law Firm, discusses the effect that the newly proposed Treasury Regulations could have on IRS whistleblower awards.
IRS Pays $38 Million on Whistleblower Claim Trend Continues Toward Faster Turnaround
Diane Freda, BNA Daily Tax Report, October 30, 2012
Gregory Lynam and Scott Knott, Tax Partners at The Ferraro Law Firm, discuss the award process and the improvements in the IRS Whistleblower Office.
Anonymous Corporate Tax Whistleblower Awarded $38 Million
Matthew Dalton, Tax Analysts, Tax Notes Today, October 29, 2012
Scott A. Knott, Tax Partner at The Ferraro Law Firm, discusses the $38 million award paid by the IRS, the process to review the proposed award determination, and the withholding agreement with the IRS.
IRS Pays Birkenfeld $104 Million Whistleblower Award
Jeremiah Coder, Tax Analysts, Tax Notes Today, September 12, 2012
Gregory S. Lynam, Tax Partner at The Ferraro Law Firm, discusses how the IRS has taken a practical approach towards the "planning and initiating" exclusion.
Whistleblower Is Key to New York Tax Probe on Buyout Firms
Reed Albergotti and Laura Saunders, The Wall Street Journal, September 12, 2012
Gregory S. Lynam, Tax Partner at The Ferraro Law Firm, discusses the involvement of whistleblowers in management-fee conversion cases.
Lower Corporate Tax Reserves Hint at Possible Effects of UTP Reporting
Jeremiah Coder, Tax Analysts, Tax Notes Today, September 11, 2012
Scott A Knott, Tax Partner at The Ferraro Law Firm, discusses the findings of the Ferraro 500, namely that while profits of the Fortune 500 has increased from the prior year that tax reserves have decreased along with collections of corporate tax.
Corporate Tax Reserves Outnumbered Actual Payments
Michael Cohn, Accounting Today, September 11, 2012
Gregory S. Lynam and Scott A. Knott, Tax Partners at The Ferraro Law Firm, discuss the Ferraro 500 and how a company's tax reserves compare to total corporate tax collections in fiscal year 2011.
Whistleblower Gets $104 Million
Laura Saunders and Robin Sidel, The Wall Street Journal, September 11, 2012
Scott A. Knott, Tax Partner at The Ferraro Law Firm, discusses the implications of Bradley Birkenfeld's award for other current and future whistleblowers.
IRS Whistleblower Office Report Cites Lower Submissions, Awards
Jeremiah Coder, Tax Analysts, Tax Notes Today, June 22, 2012
Scott A. Knott, Tax Partner at The Ferraro Law Firm, discusses how the procedural hurdles whistleblowers face from the IRS has likely caused fewer whistleblowers to come forward, and how effective representation can help a whistleblower over come those hurdles.
IRS Sets Timelines for Action on Whistleblower Claims
Jeremiah Coder, Tax Analysts, Tax Notes Today, June 22, 2012
Scott A. Knott, Tax Partner at The Ferraro Law Firm, explains why it is important that the IRS impose and adhere to the internal deadlines set in the June 20, 2012, operating directive when reviewing a whistleblower's information.
Strong IRS Headwind Blows Whistleblowers Off Course
Jeremiah Coder, Tax Analysts, Tax Notes Today, May 21, 2012
Gregory S. Lynam, Tax Partner at The Ferraro Law Firm, discusses the problem of not imposing time frames for review by a subject matter expert or the Office of Chief Counsel.
IRS Still Inattentive to Whistleblower Program Deficiencies, TIGTA Says
Jeremiah Coder, Tax Analysts, Tax Notes Today, May 11, 2012
Gregory S. Lynam and Scott A. Knott, Tax Partners at The Ferraro Law Firm, discuss how the IRS could improve its efficiency in processing whistleblower claims.
Whistleblower Petitions Tax Court to Stop IRS From Obstructing Award
Jeremiah Coder, Tax Analysts, Tax Notes Today, May 7, 2012
The Ferraro Law Firm Tax Partner, Gregory Lynam, discusses various aspects of Mr. Joseph A. Insinga's petition to the Tax Court, including whether Mr. Insinga's claim is award eligible, if the IRS has made an award determination, and what information about the taxpayer is properly included or redacted from the public filings.
Practitioners Note IRS Reversal On Paying Whistleblower Awards For Avoided Refunds
Diane Freda, BNA Daily Tax Report, February 23, 2012
Gregory S. Lynam, Tax Partner at The Ferraro Law Firm, discusses the impact of the final Treasury Regulation defining "collected proceeds" on whistleblower awards.
IRS Ignores Comments in Final Definition of Proceeds for Whistleblower Awards
Jeremiah Coder, Tax Analysts, Tax Notes Today, February 22, 2012
Scott A. Knott, Tax Partner at The Ferraro Law Firm, discusses the impact of the adoption of the final regulations for whistleblower award determinations.
Does Tax Crime Pay (Whistleblowers)?
Erica L. Brady, TAXES - The Tax Magazine, February 20, 2012
Erica Brady of The Ferraro Law Firm discusses why criminal fines and restitution payments are properly included in "collected proceeds," the amount on which the IRS pays a whistleblower award under section 7623.
Tax Court Whistleblower Anonymity Ruling Aids Informants, Foreshadows Other Changes
Diane Freda, BNA Daily Tax Report, December 12, 2011
Erica Brady of The Ferraro Law Firm discusses the Tax Court's decision to allow a whistleblower to proceed anonymously.
Whistleblower Anonymity in Tax Court Pleases Informant Representatives
Jeremiah Coder, Tax Analysts, Tax Notes Today, December 12, 2011
The Ferraro Law Firm Tax Partners, Gregory S. Lynam and Scott A. Knott, discuss the importance of the Tax Court's decision to allow a whistleblower to proceed anonymously after balancing the whistleblower's privacy concerns against the public's right to inspection.
IRS Pays $38 Million in Whistleblower Case
Laura Saunders, The Wall Street Journal, October 26, 2011
Scott A. Knott, Tax Partner at The Ferraro Law Firm, discusses a $38 million award paid to an anonymous whistleblower by the IRS for information leading to the recovery of between $127 million and $254 million in corporate taxes.
Ready to Wet Your Whistle?
Laura Saunders, The Wall Street Journal, September 14, 2011
The Wall Street Journal provides advice for people thinking about blowing the whistle on tax underpayments to the IRS.
GAO Faults IRS Whistleblower Program for Award Delays
Jeremiah Coder, Tax Analysts, Tax Notes Today, September 12, 2011
The Ferraro Law Firm Tax Partners, Scott A. Knott and Gregory S. Lynam, discuss the GAO report that highlights ways to improve the IRS Whistleblower program.
IRS Whistleblower Program Faulted
Laura Saunders, The Wall Street Journal, September 10, 2011
The Ferraro Law Firm Tax Partner, Gregory S. Lynam, discusses the GAO's recent report to Congress on the IRS Whistleblower Program which suggested improvements in timeliness and communication.
Taxes: How To Turn In Your Neighbor to the IRS
Laura Saunders, The Wall Street Journal, September 3, 2011
The Ferraro Law Firm Tax Partners, Scott A. Knott and Gregory S. Lynam, discuss the practical aspects of reporting underpayments to the IRS
Practitioners Complain of Whistleblower Award Delays, Seek Changes to IRM
Jeremiah Coder, Tax Analysts, Tax Notes Today, August 23, 2011
The Ferraro Law Firm Tax Partners, Scott A. Knott and Gregory S. Lynam, criticized the IRS's policy of delaying tax whistleblower awards as it waits for the statute of limitations to expire on refund claims and urged the IRS to update the Internal Revenue Manual to reflect more recent public guidance and allow for awards to paid sooner.
Are Criminal Fines “Collected Proceeds”?
Erica L. Brady, ABA Section of Taxation NewsQuarterly, July 23, 2011
Erica Brady of The Ferraro Law Firm discusses why criminal fines are properly included in "collected proceeds," the amount on which the IRS pays a whistleblower award under section 7623.
IRS Doubles Whistleblower Collections In 2010 While Tipsters Wait for Payouts
Diane Freda, BNA Daily Tax Report, July 21, 2011
Scott A. Knott, Tax Partner with The Ferraro Law Firm, explains how the IRS's policy to delay award determinations until after the section 6501 and section 6511 period of limitations has run has caused a significant dip in awards paid in FY 2009 and a smaller amount of awards paid relative to amounts collected within FY 2010.
IRS Whistleblower Office Reports Increased Claims, Awards Activity in 2010
Jeremiah Coder, Tax Analysts, Tax Notes Today, July 21, 2011
The IRS reported that collections as a result of their Whistleblower Program doubled to nearly half a billion dollars in fiscal 2010. The Ferraro Law Firm Tax Partners, Gregory S. Lynam and Scott A. Knott, discuss how despite this increase, the amount of award payments remain irregularly low because of a Chief Counsel decision to delay payments until after the section 6511 refund claim period has run.
Attorneys Say Recent Ruling Tests Power To Compel Audits of Whistleblower Claims
Diane Freda, BNA Daily Tax Report, June 27, 2011
Erica Brady of The Ferraro Law Firm discusses the impact of the Cooper decision and the Tax Court's jurisdiction to review all award determinations.
Tax Court Can’t Force IRS to Reconsider Whistleblower Award Denials
Jeremiah Coder, Tax Analysts, Tax Notes Today, June 21, 2011
The Ferraro Law Firm Tax Partner, Gregory S. Lynam, discusses the limits of the Tax Court's review an IRS administrative decision not to pursue an audit and why the Tax Court claimed jurisdiction over the case only to dismiss it on a motion for summary judgment.
Officials Clarify Net Operating Losses Role In Reward Calculations for Whistleblowers
BNA Daily Tax Report, May 12, 2011
Scott A. Knott, Tax Partner at The Ferraro Law Firm, expressed concern that the current guidance ignored credit balances generally and created confusion by including the specific term, "overpayment credit balances."
Speakers Complain of Narrow Proceeds Definition for Whistleblower Awards
Jeremiah Coder, Tax Analysts, Tax Notes Today, May 12, 2011
Scott A. Knott, Tax Partner at The Ferraro Law Firm, addresses a government panel regarding concerns over the definition of collected proceeds in the Proposed Treasury Regulation, specifically that the language proposed is too narrow to pick up all the situations where an award should be paid to a whistleblower. Additionally, Knott said that waiting to pay awards until the taxpayer's period of limitations for filing a refund has closed is obsolete now that awards can be paid on refund protection claims.
Practitioners Urge IRS to Attract More Whistleblowers
George L. Yaksick, Jr., CCH Federal Tax Day, May 12, 2011
Scott A. Knott, Tax Partner at The Ferraro Law Firm, encouraged the IRS to take a more expansive view of collected proceeds in the Final Treasury Regulations than they did in the Proposed Treasury Regulations, pointing out that the language may be too narrow to cover common situations in which refunds are denied in the course of a tax controversy.
A New IRS Form Brings New Risks
Katie Wagner, Agenda, May 2, 2011
Scott A. Knott, Tax Partner with The Ferraro Law Firm, discusses how the new Schedule UTP will change the risk analysis for companies required to report uncertain tax positions to the IRS and how the new reporting requirements could change IRS audits in the future.
IRS Withholding on Whistleblower Awards Ignites Controversy
Jeremiah Coder, Tax Analysts, Tax Notes Today, April 22, 2011
The Ferraro Law Firm Tax Partners, Scott A. Knott and Gregory S. Lynam, discuss the pitfalls of the IRS's decision to withhold on whistleblower awards absent statutory authority for such withholdings. Knott also discusses the IRS's position to exclude criminal fines from collected proceeds, characterizing PMTA 2010-60 as "a proverbial line in the sand on the issue," and the issue will likely have to be litigated. Lynam also discusses the ability of anonymity procedures to prevent the target taxpayer's information and the whistleblower's information from being disclosed during review by the Tax Court.
IRS Issues Final Regs On Disclosure Of Return Information To Whistleblowers
George L. Yaksick, Jr., CCH Newsletter, Federal Tax Weekly, March 17, 2011
Scott Knott, Tax Partner with The Ferraro Law Firm, explains how the finalization of the section 6103(n) regulations will have a minimal impact on whistleblowers because the IRS is not entering into section 6103(n) agreements either out of extreme caution bordering on neglect, a failure of internal communications, or both.
Treasury Finalizes Whistleblower Contract Regs but Isn’t Using Them
Jeremiah Coder, Tax Analysts, Tax Notes Today, March 15, 2011
The Ferraro Law Firm Tax Partners, Gregory S. Lynam and Scott A. Knott, discuss the failure of the IRS to enter into section 6103(n) agreements with whistleblowers, missing an opportunity to fully utilize the whistleblower's inside knowledge and tax expertise.
IRS Finalizes Whistleblower Rules Requiring Contract for Disclosure of Return Information
Diane Freda, BNA Daily Tax Report, March 15, 2011
Erica L. Brady of The Ferraro Law Firm discusses how the IRS is squandering an opportunity by failing to enter into section 6103(n) agreements with whistleblowers.
IRS Pays First Enhanced Whistleblower Award
Jeremiah Coder, Tax Analysts, Tax Notes Today, March 15, 2011
Finally. Scott A. Knott and Gregory S. Lynam, Tax Partners with The Ferraro Law Firm, discuss additional issues that have been raised and what we have learned about how the IRS is handling award payments from the first publicized award payment.
New Offshore Voluntary Disclosure Initiative Features 25 Percent Penalty, Greater Clarity
Marie Sapirie, Tax Analysts, Tax Notes Today, February 9, 2011
Gregory S. Lynam, Tax Partner at The Ferraro Law Firm, discusses why whistleblowers will remain an integral part of enforcement of tax laws where an individual actively sought to avoid taxes and is hiding money offshore.
Federal Claims Court Chides IRS for Erroneous Whistleblower Appeals Instructions
Jeremiah Coder, Tax Analysts, Tax Notes Today, February 2, 2011
The Ferraro Law Firm Tax Partners, Gregory S. Lynam and Scott A. Knott, discuss a whistleblower's award determination appeal rights under the 2006 amendments to section 7623(b).
Panelists Say IRS Asserting No Appeal When Whistleblower Claim Not Pursued
Alison Bennett, BNA Daily Tax Report, January 24, 2011
Erica Brady from The Ferraro Law Firm discussed at an American Bar Association Tax Section Conference how whistleblower claims are processed by the IRS.
Proposed Regs Expand Definition Of Proceeds Collected Under IRS Whistleblower Rules
George L. Yaksick, Jr., CCH Newsletter, Federal Tax Weekly, January 20, 2011
The Ferraro Law Firm Tax Partner, Gregory S. Lynam, explains that while the proposed regulations expand the definition of collected proceeds, the proposed regulations are vague and may or may not cover any number of scenarios involving credit carrybacks or carryforwards, and other taxpayer-favorable adjustments.
IRS Proposes Expanded Definition for Whistleblower Awards
Jeremiah Coder, Tax Analysts, Tax Notes Today, January 18, 2011
The Ferraro Law Firm Tax Partners, Gregory Lynam and Scott Knott, discuss the proposed regulations that expand the definition of collected proceeds, and the need for additional guidance to clarify when an award is available and how it will be determined.
IRS Alters Rules to Pay Informants in More Cases
Ryan J. Donmoyer, Bloomberg BusinessWeek, January 14, 2011
This article discusses the change in the IRS's reversal of an earlier position through the publication of proposed treasury regulations, making it more likely that an informant will collect a reward when they come forward.
IRS Whistleblower Office Reports High Submissions, Omits Controversial Issues
Jeremiah Coder, Tax Analysts, Tax Notes Today, December 15, 2010
The Ferraro Law Firm Tax Partners, Gregory S. Lynam and Scott A. Knott, discuss how now, before the IRS begins to pay awards, is the best time to come forward with information because they expect that once the IRS begins to pay awards the IRS Whistleblower Office will be inundated with submission, while now the number of submissions is relatively flat.
Practitioners Disagree Over Effect of UTP Reporting on Whistleblower Claims
Jeremiah Coder, Tax Analysts, Tax Notes Today, September 1, 2010
The Ferraro Law Firm Tax Partner, Gregory S. Lynam, discusses the effect the new UTP reporting rules on future whistleblower claims.
IRS Plan to Uncover Companies’ Tax Strategies
David Kocieniewski, The New York Times, August 24, 2010
Fortune 500 companies' reserves for uncertain tax positions were approximately $200 billion, according to The Ferraro 500, a database ranking the Fortune 500 companies by their tax reserves. The IRS plans to mandate that corporations disclose their uncertain tax positions.
IRS Issues Whistleblower Award Determination Procedures
Jeremiah Coder, Tax Analysts, Tax Notes Today, June 18, 2010
The new IRS whistleblower award procedures were analyzed by The Ferraro Law Firm Tax Partners, Scott A. Knott and Gregory S. Lynam.
IRS Rolls Out Long-Awaited Procedures for Making Tax Whistleblower Awards
Lauren Gardner, BNA, Daily Tax Report, June 18, 2010
The Ferraro Law Firm Tax Partner, Gregory S. Lynam, commented on the award procedures released by the IRS.
IRS Whistleblower Guidelines Spark Criticism
Martin Vaughan, Dow Jones Newswires, June 18, 2010
U.S. Senator Charles E. Grassley (R., Iowa) and The Ferraro Law Firm Tax Partner, Gregory S. Lynam, commented on the new IRS whistleblower award procedures.
Americans Seeking Reward Money Inform IRS on Others
Ryan J. Donmoyer, Bloomberg.com, May 4, 2010
At a conference in Miami, IRS Whistleblower Office Director said that the IRS is close to issuing guidance on how it is going to pay out awards to tax whistleblowers.
IRS Gives Tax Informants More Bites
Arden Dale, Dow Jones Newswires, February 26, 2010
The Ferraro Law Firm Tax Partner Scott A. Knott and IRS Whistleblower Office Director Stephen Whitlock commented on the recent favorable changes in IRS procedures for handling cases that involve taxpayer insiders as whistleblowers.
Chief Counsel Approves More Interaction With Whistleblowers
Jeremiah Coder, Tax Analysts, Tax Notes Today, February 24, 2010
The IRS has revised its stance toward whistleblower information submitted by informants who are current employees of the organization. The Ferraro Law Firm Tax Partners Scott A. Knott and Gregory S. Lynam discuss how this change in policy will remove roadblocks and allow the IRS to use all of the information a current employee, who is in rightful possession of such information, is willing to provide.
Tax Informants Are On The Loose
Janet Novack and William P. Barrett, Forbes.com, December 14, 2009
In this article, The Ferraro Law Firm Tax Partner Gregory S. Lynam points out the necessity of tax informants to identify weak links in complex transactions designed to avoid U.S. taxes.
Tax Whistle-Blowing: Many Cases, Few Results
Jeremiah Coder, Tax Analysts, Tax Notes Today, October 9, 2009
The Ferraro Law Firm Tax Partners Gregory S. Lynam and Scott A. Knott discuss their experiences representing clients in tax whistleblower cases.
IRS Whistleblower Claims Quadruple on Informants
Ryan J. Donmoyer, Bloomberg News, October 1, 2009
Submissions to the IRS Whistleblower Office quadrupled between fiscal 2007 and 2008; mentioned is the Washington, D.C. office of The Ferraro Law Firm which was opened to handle these cases.
Teed Off Residents Drive Developer to Brink of Ruin
William M. Buckley, The Wall Street Journal, September 24, 2009
A client of The Ferraro Law Firm, Dr. Michael Lissack, discussed his submission to the IRS Whistleblower Office alleging that a developer underpaid $100 million in taxes by not taking membership deposits into income.
Proposed Regs on Contingent Fees Incorporate Interim Guidance
Jeremiah Coder, Tax Analysts, July 28, 2009
The Ferraro Law Firm Tax Partner, Gregory S. Lynam, offers insights into why allowing contingency fees for whistleblower cases is consistent with the overall ban of contingency fees for tax-related fees.
International Cases Contribute to Dramatic Increase in Whistle-Blowers, U.S. Reports
David D. Stewart, Tax Analysts, Tax Notes Today, February 2, 2009
The Ferraro Law Firm Tax Partner Scott A. Knott and IRS Whistleblower Office Director Stephen Whitlock gave a presentation about tax whistleblowers and international tax issues at the Florida Bar Tax Section/FICPA Meeting in Miami.
Experts Predict Tax Court’s Amended Rules May Encourage Whistleblower Actions
George L. Yaksick, Jr., CCH Newsletter, Federal Tax Weekly, October 16, 2008
The Ferraro Law Firm Tax Partners Gregory S. Lynam and Scott A. Knott commented on the new sections of the U.S. Tax Court Rules of Practice and Procedure that relate to whistleblower actions.
Tax Court Amends Whistleblower Rules
WebCPA staff, WebCPA.com, October 14, 2008
Comments to the Tax Court filed by The Ferraro Law Firm and others led to an acknowledgement by the Court that the identity of a whistleblower appealing their award should be protected.
IRS Whistle-Blower Office Sees Huge Jump in Claims, Official Says
Jeremiah Coder, Tax Analysts, Tax Notes Today, September 16, 2008
The Ferraro Law Firm Tax Partner Gregory S. Lynam and IRS Whistleblower Office Director Stephen Whitlock were quoted as panelists of a discussion about tax whistleblowers at the American Bar Association Tax Section Meeting in San Francisco.
Tax Collection: Whistleblower Tips Keep Coming; Program Future Unclear; Awards Remain Mystery
Laura Mahoney, BNA, Daily Tax Report, September 16, 2008
The Ferraro Law Firm Tax Partner Gregory S. Lynam and IRS Whistleblower Office Director Stephen Whitlock provided insights and updates on the IRS Whistleblower Program at the American Bar Association Section of Taxation meeting in San Francisco.
Practitioners Want More IRS Interaction With Whistle-Blowers Making Claims
Jeremiah Coder, Tax Analysts, Tax Notes Today, August 15, 2008
The Ferraro Law Firm Tax Partners Scott A. Knott and Gregory S. Lynam commented on the state of the IRS procedures for handling whistleblower claims in large corporate cases.
Why the Work of In-House Accountants is NEVER Subject to the Tax-Practitioner Privilege of Section 7525
Gregory S. Lynam, Tax-Whistleblower.com, June 30, 2008
Can you turn over to the IRS documents prepared by accountants directly employed by the taxpayer? This article addresses why the tax-practitioner privilege of section 7525 does not apply to the work of in-house accountants.
Law Firm Submits New Record Whistle-Blower Claim
Jeremiah Coder, Tax Analysts, Tax Notes Today, June 16, 2008
The Ferraro Law Firm in a June 13 press release announced it was submitting a $4.4 billion tax whistle-blower claim against a Fortune 500 company.
Friday the 13th Poses $4.4 Billion of Bad Luck for Fortune 500 Company
The Ferraro Law Firm, PR Newswire, June 13, 2008
The Ferraro Law Firm filed a new record tax whistleblower submission of more than $4.4 billion to the IRS Whistleblower Office.
Law Firm Files First $4 Billion Tax Whistleblower Submission with IRS
Paul Caron, TaxProf Blog, June 13, 2008
The Tax Prof blogs a record $4.4 billion tax whistleblower submission regarding a Fortune 500 company.
Tax Whistleblower Action Claims $4.4 Billion Tax Underpayment by Fortune 500 Company
The Ferraro Law Firm, BNA, June 13, 2008
A submission to the Internal Revenue Service Whistleblower Office alleges that a Fortune 500 company has underpaid its U.S. tax liability by more than $4.4 billion--over a short period of time--by engaging in abusive tax transactions, an attorney representing the whistleblower announced June 13.
Tax Court Proposes New Rules For Electronic Service, Whistleblower Claims
George L. Yaksick, Jr., CCH Newsletter, Federal Tax Weekly, June 12, 2008
The U.S. Tax Court recently proposed amendments to its Rules of Practice and Procedure to encompass electronic service of filings.
Whistle Blower Regs Allow Limited Return Information Disclosure
Jeremiah Coder, Tax Analysts, Tax Notes Today, March 26, 2008
The IRS issued temporary and proposed regulations on March 24 that will allow some measure of tax return information disclosure to whistleblowers.
IRS Whistleblower Office Receives $4 Billion in Submissions from One Law Firm
The Ferraro Law Firm, PR Newswire, January 11, 2008
The Ferraro Law Firm filed a tax whistleblower submission of more than $600 million to the recently created IRS Whistleblower Office.
Tipster Rewards Require Patience
Tom Herman, The Wall Street Journal, December 26, 2007
Blowing the whistle on big-time tax cheats could make some informants wealthy -- as long as they have hard evidence and plenty of patience.
Law Firm Files First $2 Billion Tax Whistleblower Submission with IRS
Paul Caron, TaxProf Blog, December 12, 2007
The Tax Prof blogs a record $2 billion tax whistleblower submission regarding one of the world's largest companies.
Record $2 Billion Tax Whistleblower Submission Filed
The Ferraro Law Firm, PR Newswire, December 11, 2007
The Ferraro Law Firm submitted a tax whistleblower submission of more than $2 billion to the recently created IRS Whistleblower Office.
IRS Can Pay Large Awards to Nearly Anyone for Information About Tax Underpayments
Scott A. Knott and Gregory S. Lynam, Tax-Whistleblower.com,, October 23, 2007
Amended 26 USCA 7623 of the Internal Revenue Code now provides that persons who have information about underpayments of tax or violations of the Code who provide that information to the IRS can receive substantial cash awards.
Accounting Ethics Rules Give In-House CPAs the Green-Light to Blow the Whistle
Scott A. Knott and Gregory S. Lynam, Tax-Whistleblower.com, October 23, 2007
Professional advisors representing companies or wealthy individuals who have discovered information about large tax underpayments have a strong financial incentive to use the high quality information obtained while servicing the taxpayer in a submission to the IRS Whistleblower Office.
Tax Whistleblower Action Claims $1 Billion Underpayment by Fortune 500 Company
J.P. Finet, BNA, October 12, 2007
A submission to the Internal Revenue Service Whistleblower's Office alleges that a Fortune 500 company represented by Ernst & Young LLP entered into a series of transactions to improperly reduce its taxes by more than $1 billion, two attorneys representing the whistleblower told BNA Oct. 11.