Articles: 1-10 of 22
IRS Announces Settlement Initiative for Syndicated Conservation Easement Cases Pending in Tax Court
USA - June 24 2020 On June 25, 2020, the Internal Revenue Service announced a settlement initiative available to certain taxpayers with pending Tax Court cases involving…
BACK TO BASICS, Continued—Electronic Signatures
USA - June 16 2020 I wrote a blog about doing business electronically last year. See the blog here. I want to revisit this issue with you because of the COVID-19…
Bitcoin and Virtual Currency Traders Beware - the IRS Is Coming for Your Coins and More
USA - July 29 2019 The Internal Revenue Service announced Friday that it is sending informaonal leers to taxpayers who may have failed to report transacons involving…
Notice 2018-006: How will the Government comply with Section 6751(b)?
USA - June 28 2018 A string of recent tax cases have stirred up confusion around what steps the IRS must take before it can assess penalties against taxpayers. These…
“Physical Presence Test” For Sales Tax Collection Overturned in Bombshell Supreme Court Case
USA - June 21 2018 Disregarding 26 years of precedent barring states from taxing out-of-state sellers unless they had a “physical presence” within the state seeking to…
Texas Judge Caps FBAR Penalties: Shuts Down IRS Attempt to Skirt Its Own Regulations
USA - June 14 2018 In an unusual turn of events, the IRS argued that its own regulation was outdated and therefore invalid when urging a Texas district court to impose…
IRS Targets Partnership for Audits According to New Compliance Initiative
USA - April 2 2018 Last week, the IRS announced five new compliance campaigns. Through these campaigns, the IRS will be focusing on certain issues in its identification…
Time is Running Out to Disclose Foreign Accounts to the IRS
USA - March 15 2018 Since 2009, the IRS has put into place a series of disclosure program that allows taxpayers to come forward and disclose their foreign financial…
Taxpayer Notice: IRS Interest Rates are Increasing on Refunds and Deficiencies
USA - March 13 2018 The IRS interest rate on underpayments (e.g., deficiencies) and overpayments (e.g., refunds) are increasing for the first time in quite a while. For…
Tax Court and Second Circuit Disagree on What Amounts to Timely Managerial Approval of Penalties: Chai v. Comm'r, 851 F.3d 190 (2nd Cir. 2017) versus Graev v. Comm'r, 147 T.C. No. 16 (2016).
USA - November 13 2017 When imposing certain penalties, the IRS is required to comply with Code section 6751(b)(1), which provides: No penalty under this title shall be…
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