{ Banner }

Tax Blog

  • Posts by Larry A. Campagna
    Shareholder
    | 713.654.9609

    Larry Campagna has an established reputation as an authoritative litigator in matters of business litigation, white-collar criminal defense, and particularly in federal, state and local tax controversies. For more than 45 ...

    Full Bio
A New IRS Voluntary Disclosure Program Is Coming: What We Know So Far
Posted September 15, 2026 by Larry A. Campagna

For more than three-quarters of a century, the IRS has had some form of a Voluntary Disclosure Program.  These programs have invited non-compliant taxpayers who have willfully cheated the government to make amends and come back into compliance.  In return, the taxpayer benefits from reduced penalties and non-prosecution in return for self-reporting.  On August 25, 2026, the IRS Criminal Investigation Chief announced that the IRS would release within the next 60 days a new version of the Voluntary Disclosure Program.  That announcement has been long awaited and sorely needed.

The ...

Read More
Categories: Tax Penalties, Tax Procedure, Tax Relief
Share
Members of Tax Controversy & Litigation Practice File Comments on Proposed Employee Retention Credits Regulations
Posted August 19, 2024 by Larry A. Campagna, Tom Cullinan, John W. Hackney, Philip Karter, Samuel T. Kuzniewski, Kristen S. Lowther, Charles Rettig, Kevin F. Sweeney, Leo Unzeitig, Jaime Vasquez, Victor J. Viser

Members of our Tax Controversy & Litigation practice filed comments last week on the proposed regulations published July 2, 2024, regarding the Employee Retention Credits. They argued that these proposed regulations exceed the IRS and Treasury authority. They also urged these bodies to abandon the current proposed regulations as they relate to the ERC, and to reconsider the appropriateness of the final regulations treating excessive ERC refunds as underpayments of tax, particularly in light of the Supreme Court's recent decision in Loper Bright Enterprises v. Raimondo. 

Read ...

Read More
Share