The contours of various privileges (attorney-client, attorney work product, spousal, etc.) vary from one jurisdiction to another domestically from whether each privilege exists to who holds (or “owns”) the privilege to how it is waived or preserved. Putting those issues into cross-border transactions and negotiations
The IRS can fill out a substitute return for you—and it usually isn’t accurate. And a lot of penalties and interest will accrue. Even if you don’t go to jail, blowing off the Internal Revenue Service is a really bad idea. Take Larry Cecil Cabelka
By Megan L. Brackney Practical Tax Strategies February 01, 2014 A client calls his long-time, trusted accountant, and nervously says: “There is something I need to talk to you about. Can I come in to see you? I don’t want to talk about it over the
By Caroline Rule BNA Tax Management Portfolio No. 623-3rd July 26, 2013 Tax Management Portfolio, IRS Procedures: Examinations and Appeals, No. 623-3rd, describes and discusses the law applicable to, and the policies and procedures followed by, the IRS in the examination of tax returns and administrative
By Brian P. Ketcham WG&L Journal of Taxation May 2013 Edition An unexpected new development casts doubt about the future success of the Service’s major initiative in the campaign against hidden offshore accounts. Even more distressing are the implications for taxpayers in general about trusting IRS
