Jonathan R. Black is an Associate in the Tax Controversy practice group. Prior to private practice, Mr. Black served as an attorney with the Office of Chief Counsel for the Internal Revenue Service, where he defended the IRS in Tax Court, drafted regulations and other published guidance, and advised the IRS and the Department of Justice on a myriad of legal issues. He also provided IRS attorneys training on administrative law and legal ethics.
Services
Mr. Black advises individuals and businesses on a wide range of matters relating to compliance with their U.S. tax obligations, including:
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information reporting obligations;
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FBAR compliance;
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penalties and reasonable cause; and
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streamlined filing procedures and voluntary disclosure.
Highlights
While attending Cornell Law School, Mr. Black was an Editor for the Journal of Law and Public Policy. He also served as a Judicial Intern at the United States Bankruptcy Court for the Northern District of New York.
Mr. Black is fluent in Chinese and has fundamental knowledge of Japanese.
Recent News
Click here for a full list of media coverage.
Speaking Engagements
- Panelist, Focus on Tax Practitioners: Ethical and Penalty Issues, 13th Annual NYU Tax Controversy Forum, June 24, 2021
- Moderator, IRS Ethics Interactive Video Training 2019, IRS, May 30, 2019
- Panelist, Court Procedure & Practice Roundtable Discussion: Failure to Provide Information Returns and Litigation, 2019 ABA Section of Taxation May Meeting, May 11, 2019
Click here for a full list of speaking engagements.
Recent Publications
- "Damage Mitigation: The IRS Helps Alleviate Effect of COVID-19 on U.S. and Foreign Residency,"
with Victor A. Jaramillo, Caplin & Drysdale Client Alert, April 22, 2020
- "Partnership Filing Relief,"
with Mark D. Allison, Christopher S. Rizek, Charles M. Ruchelman, and James E. Salles, Caplin & Drysdale Client Alert, April 13, 2020
- "Captive Soft Letter,"
with Christopher S. Rizek and Charles M. Ruchelman, Caplin & Drysdale Client Alert, March 31, 2020
- "BLOG: IRS Releases Interim Guidance on BBA Partnership Audit Procedures,"
with Charles M. Ruchelman, www.PartnershipRepresentative.com, October 24, 2019
Click here for a full list of publications.