In recent years, it’s almost become an annual ritual, waiting to find out at the end of the year whether Congress will continue various temporary tax breaks known as “tax extenders.” It happened last year and the year before that. This year, however, things are a bit different. Congress adjourned […]
The internet – and the burgeoning digital marketplace it has created – has broadened horizons and opened doors that wouldn’t have been imagined just a generation ago. With just a few clicks of a mouse, you can do business with companies across town or across the globe. This brave new […]
“A rose by any other name would smell as sweet,” goes Shakespeare’s famous line from Romeo and Juliet. The idea is the essence of thing is what matters, apart from the name it is given. Still, names for things do contain important distinctions. In this post, let’s consider the distinction […]
Few groups within the IRS have been spared cuts as funding has failed to keep up with inflation. After losing almost 21 percent of its staff between 2012 and 2015, Appeals has needed to reorganize. Three functional offices – Collection, Examination and Specialized Examination Programs and Referrals – replace two […]
Sometimes tax litigation can’t be avoided. When the IRS is being unreasonable, you need to protect your interests. In other situations, however, it may make sense for both sides to come to an agreement. The IRS seems to realize this too and recently made changes to its mediation procedures. More […]
A multinational World Trade Organization panel recently found that Washington State offered aviation company Boeing nearly $9 billion in “prohibited” tax breaks, benefits and subsidies to keep production of the massive 777x aircraft within its borders. The WTO panel investigated the arrangement as part of an ongoing business dispute between […]
Many changes await Americans next month when a new presidential administration and a new Congress take office. It’s no secret that those changes are likely to include a tax cut. But it’s also important to be aware that an overhaul of how deductions are handled is also under serious discussion. […]
A conviction for criminal tax evasion carries serious penalties, including a stint in federal prison, hefty fines and the costs of government prosecution. Then there is the negative impact on business or individual reputation and the limitations that a criminal record can impose on future opportunity. The role of banks […]
Willfulness is usually required to support criminal charges. Assigning signature authority to someone else to conceal account ownership could show willful conduct. Filing a document, such as a Foreign Bank and Financial Accounts/FinCEN Report 114 (FBAR) with false information is another. A five year prison sentence is on the table […]
It seems so basic: Did you file a return or didn’t you? Rather remarkably, however, even this seemingly straightforward question can result in litigation. In this post, we will discuss a recent case in which one of the issues was proving that a return was filed. The case is called […]