Richard Blumenthal has extensive experience in international and domestic taxes, having spent a 35+ year career with the IRS. His background includes positions throughout many areas of the IRS including Large Business & International (LB&I), Small Business Self Employment, and the IRS Abusive Transactions group. Richard has extensive experience in resolving domestic and foreign corporate, partnership, individual tax and penalty cases at the field, manager and territory manager levels.
During his career, Richard was responsible for developing the IRS’s international foreign owned business compliance strategy, which included implementation of international inbound campaigns, field technical support and compliance with the 2017 Tax Reform Job Act (TCJA). Richard developed various IRS enforcement campaigns by data analysis to identify compliance issues on forms 1120F, 1120, 1040NR and partnership Form 1065. The campaigns included 1120F Non-Filer & Protective return, 1120F Delinquent Return, and Financial Entities involved in Lending Activities. Richard lead the classification and audit guides for these campaigns, which included procedures on handling delinquent Form 1120-F and requests for waiver of disallowance of expenses on delinquent F 1120-F.
Richard’s TCJA compliance included development of forms and instructions for the base erosion, sale of partnership interest by foreign partners, and business interest expenses limitation. The form development included the foreign partner sections of the new Form 1065 K-2, K-3 Partner’s share of Income, Deductions, Credits. Richard also modified the Form 1099S and 1099 Dividend to increase the identification of foreign investors selling U.S. real property subject to FIRPTA.
Richard’s experience also included the resolution of multiple transfer pricing issues in the areas of cost sharing, Subpart F, multinational corporations, and high wealth individuals. He recently led the LB&I field examination team in a precedent-setting case involving the assessment of § 956 income on a controlled foreign corporation ‘s guarantee of a US shareholder loan on its earning and profits, with the Tax Court and the Third Circuit sustaining the IRS assessment on the complex investment firm. (SIH Partners LLP v. Comm. 150 TC NO 3, 3d Cir 2019).
Richard also participated as a member of the faculty cadre in various offshore abusive tax avoidance transaction training courses. He has extensive experience with penalty and tax resolution in the area of international information returns on Forms 5471, 5472, and 8833 as well as the significant issue of management approval for examination penalties. He was a successful expert witness on a FIRPTA and treaty shopping case in Bota NV v. Comm. NO 1842 -88, and assisted the U.S. Department of Justice in the conviction of an offshore treasury bill shelter.
Academic Degrees & Licenses/Admissions
- B.A. Florida State University
- Florida State CPA
Awards & Honors
- Three (3) Internal Revenue Service Commissioner Awards
- 2 Assistant Commissioner (Examination) Awards
- Numerous other I.R.S. Awards and Commendations