By Christopher M. Ferguson Law.com May 12, 2020 Once the May 14 deadline for arguably undeserving recipients of PPP loans to return the funds “no questions asked” has passed, the government will no doubt seek to make examples of undeserving PPP loan recipients. For anyone following
By: Robert S. Fink LexisNexis 39th Ed. 2020 The 39th edition of “Tax Controversies: Audits, Investigations, Trials” has been published and is available on Lexis-Nexis. Authored by Kostelanetz & Fink co-founder Robert S. Fink and the attorneys of Kostelanetz & Fink, Tax Controversies is the recognized guide to
By Megan L. Brackney Tax Notes Federal April 27, 2020 Given that combating tax fraud is a top agency priority, it is a good time to review the law and procedures related to tax fraud. In this article, Megan Brackney discusses the ways the IRS identifies
By Nicholas S. Bahnsen The CPA Journal April 2020 Edition In March 2020, the IRS announced an exemption to the information reporting requirements applicable to foreign trusts. Under this exemption, qualified individuals no longer need to report transactions with or ownership of applicable tax-favored foreign trusts
By Caroline D. Ciraolo Journal of Tax Practice and Procedure Spring 2020 Edition At the 35th Annual UCLA Extension Tax Controversy Institute, Caroline D. Ciraolo and her fellow panelists addressed international tax compliance and enforcement, including what’s old, what’s new and what we can expect going forward.
By Christopher M. Ferguson NYSSCPA Tax Stringer April 1, 2020 On Sep. 28, 2018, the IRS’s Offshore Voluntary Disclosure Program (OVDP) came to an end; however, offshore tax and reporting noncompliance persists in today’s increasingly global economy. Tax advisors are still helping clients who have been—or
Caroline Rule’s article, “United States v. Greenfield: A Triumph of the Fifth Amendment’s Act of Production Privilege; or Confirmation that the Privilege Can Be Entirely Abrogated by Any Act of Congress, or Even by a Treasury Regulation?” published in The Tax Lawyer, Winter 2018 (71:2),
By Caroline Rule and Bob Fink Law 360 Twenty years ago, we put forward what was then a novel concept — that the IRS and the U.S. Department of Justice were misusing the tax code to make their jobs easier. Our topic was the misuse of a statute that, we contended, was
By Megan L. Brackney Tax Notes In this article, Brackney discusses the John Doe summons procedures and the decision partially enforcing a John Doe summons in Coinbase. She also identifies some practical considerations for taxpayers whose information may be turned over to the IRS in accordance with
By Juliet L. Fink The CPA Journal March 2020 Edition Section 7623 of the Internal Revenue Code (IRC) allows for the payment of financial awards to those who blow the whistle on individuals or corporations that have deliberately underreported or underpaid their taxes. Such awards are
