Alon Farhy was not the most sympathetic of taxpayers. That may explain why the D.C. Circuit was inclined to decide against him. He failed — perhaps intentionally — to file several tax forms for 2004 and subsequent years, for which the IRS eventually assessed penalties of nearly $500,000. The Tax Court held in Farhy’s favor, based on an unbiased (albeit incomplete) analysis of the relevant law. On appeal, the D.C. Circuit was apparently incapable of such judicial restraint, deciding against the admittedly noncompliant Farhy after a cursory analysis of what it thought to be the relevant law.
In an article published in Tax Notes Federal, Kevin M. Jacobs, Brendan Sinnott and Kenneth Brewer analyze the decision's impact on tax law interpretation and advocate for fair treatment of taxpayers.
READ THE TAX NOTES ARTICLE
Overview of the BMF Instruction Sheet on Cross-Border Audit Cooperation
July 24, 2025
With its updated instruction sheet on cross-border audit cooperation, the German Ministry of Finance signals a stronger focus on coordinated tax enforcement. Joint and simultaneous audits are gaining relevance – especially in transfer pricing matters. For multinational groups, this means greater pressure to ensure consistency and audit readiness across jurisdictions.
PMK 37/2025: New Indonesia Regulation on Withholding of Article 22 Income Tax by E-Commerce Platforms
July 23, 2025
Learn how PMK 37, Indonesia's new e-commerce income tax regulation, expands the tax base and modernizes tax collection procedures under Article 22.
Announcement to Delay Tariffs to August 1, 2025: Implications for Pan-Asia Region
July 24, 2025
With US tariffs set to commence on August 1, 2025, discover the implications for affected Pan-Asia countries.
Alvarez & Marsal Tax Launches Indonesia Tax Practice Led by Jaap Zwaan
July 22, 2025
Alvarez & Marsal Tax, (A&M Tax), an affiliate of leading global professional services firm Alvarez & Marsal (A&M), today announced the launch of its Indonesia tax practice, further strengthening its presence in Asia.
