§ 5321(a)(5) (2004) that currently are before the United States Court of Appeals for the Federal Circuit in a pending appeal: (1) whether the Internal Revenue Service (“IRS”) must establish that a taxpayer had knowledge of the legal duty under federal tax law to report foreign bank accounts, but acted in “reckless disregard” of that duty, before it may impose a civil penalty for a willful violation of 31 U.S.C. [read post]

Key Findings The Ohio Commercial Activity Tax, a 0.26 percent tax on business gross receipts above $1 million, is a throwback to an earlier era of taxation, bringing back a tax type that had been in steady retreat for nearly a century. [read post]