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 […]
The IRS’s budget has been going down, not up. These cuts have made the agency less able to play its accustomed customer-service role in helping taxpayers comply with the U.S. tax code. To be sure, the IRS also has its enforcement side, with penalties, audits, investigations and collection actions. Could […]
College athletes still aren’t paid (other than receiving scholarships). But the role of agents and advisers is very important in helping players procure pro contracts and managing their money if and when they do. Like other financial advisers, those who represent athletes can run afoul of tax authorities. In this […]
Federal regulation of businesses is poised to change with the new administration, with important implications for tax compliance. President-elect Trump has promised to roll back business regulation across the board. And with his surprising victory this week, he is in a position to put that promise into practice. But it […]
The IRS has reportedly received more than 8,000 public comments regarding proposed changes to how the agency determines valuation discounts under Section 2704 of the U.S. Tax Code. This provision, contained in Reg-163113-02 of the agency’s regulations, deal with discounts allowed for valuation of business holdings and assets for purposes of calculating […]