Jonathan R. Black is a Member of Caplin & Drysdale's Tax Disputes & Tax Litigation and Complex Litigation practice groups where he advises on tax compliance and reporting obligations, strategizes with clients to defend IRS audits, and assists with investigations and litigation. Prior to joining Caplin & Drysdale, 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. In addition to his decade of experience in tax law and litigation, Mr. Black has prior careers in property development, procurement, and analytics.
Services
Mr. Black advises individuals and businesses on a wide range of matters relating to compliance with their U.S. tax obligations, including:
- audit assistance, IRS Independent Office of Appeals (“Appeals”) negotiation, and litigation;
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information reporting obligations;
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FBAR compliance;
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penalties and defenses; and
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streamlined filing procedures and voluntary disclosure.
Highlights
Mr. Black has negotiated full IRS concessions and abatements on matters including millions of dollars in penalties for failure to file foreign information reports (including Form 3520, Annual Return To Report Transactions With Foreign Trusts and Receipt of Certain Foreign Gifts, and Form 3520-A, Annual Information Return of Foreign Trust With a U.S. Owner) and various asserted income tax deficiencies.
Admissions & Education
Bar & Court Admissions
- District of Columbia
- New York
- U.S. Tax Court
- U.S. Court of Federal Claims
Education
J.D., Cornell Law School, 2014
P.B.C., Minzu University, 2008
B.A., University of Oregon, 2005
Languages
- Mr. Black is fluent in Chinese and has fundamental knowledge of Japanese.
Government Service
Attorney, Office of Chief Counsel, Internal Revenue Service, 2014-2019
Judicial Intern, Honorable Margaret M. Cangilos-Ruiz, U.S. Bankruptcy Court (N.D.N.Y), 2013
