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2013 Ferraro 500 list ranks Uncertain Tax Positions

We released the Ferraro 500 today.  The Ferraro 500 is a reorganization of the Fortune 500 by the size of the companies' Unrecognized Tax Benefit reserve ("Tax Reserve") for uncertain tax positions reported in SEC filings.  The 2013 Ferraro 500 showed that...

What’s the biggest threat to IRS Whistleblower claims?

I bet that every person reading this blog - people with an interest in the IRS Whistleblower Program - has seen that the IRS has been under fire this summer due to the exempt organization application processing scandal, and is wondering how this situation impacts...

Whistleblowers in Quandary Over Potential Whipsaw

The IRS has spent much time ensuring that they would not be whipsawed by paying an award on proceeds that is ultimately refunded to the taxpayer, but apparently, little consideration has been given to what happens when the IRS whipsaws a whistleblower using their...

Just in Time for the New Year…New Proposed Regulations

Proposed Treasury Regulations for the IRS whistleblower program were released on December 14, 2012.  These regulations cover many issues and deserve a complete reading; however, below is a short outline of what each section of the proposed regulations covers....

IRS Whistleblower Awarded $38 Million.

We are excited to share some good news … the IRS has awarded $38,037,899 to one of our clients for providing information about a tax avoidance scheme perpetrated by one of the nation’s largest corporations.  We respect our client’s wishes...

UBS Whistleblower gets paid $104 million award from IRS.

Congratulations to Brad Birkenfeld for receiving a $104 million award from the IRS for turning in UBS for their offshore banking practices. Kudos to Steve Kohn and Dean Zerbe, his counsel since 2009 on this matter. It appears that Birkenfeld’s award...

Lynam Knott