Protected: Planning and Tax Considerations for Collectibles: Assisting Hobbyists, Dealers, and Investors
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Protected: PFP | Analyzing an Investment Manager’s Proposal
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Navigating ERC Tax Audits and Investigations: Part One
By Christopher M. Ferguson CCH Journal of Tax Practice & Procedure Fall 2023, Volume 25, Issue 3 Over the past three and a half years, countless businesses have availed themselves of the Employee Retention Credit (“ERC”), a tax credit intended to incentivize businesses to retain
The Supreme Court Will Determine Constitutionality Of The Mandatory Repatriation Tax
By Caroline Rule ABA Tax Times Volume 42, No. 4 – Summer 2023 In the next Supreme Court term, the Justices will hear argument on whether the Mandatory Repatriation Tax (MRT), violates the Sixteenth Amendment. Depending on how the Court decides this issue, the case
ChatGPT for Legal and Tax Professionals
By Garrett L. Brodeur, Grace Hall, and Ella Tynch CPA Journal September 2023 Since the introduction of ChatGPT in November 2022, artificial intelligence (AI) has taken the legal and accounting professions by storm. The use of AI in legal proceedings has already made headlines and research
Trump Cases Put the Crime-Fraud Exception in the Spotlight
By Sharon L. McCarthy and Daniel C. Davidson New York Law Journal September 15, 2023 “Attorney-client privilege is dead!” So declared then-President Donald Trump in a tweet after a 2018 law enforcement raid on his former lawyer Michael Cohen’s office. In fact, various investigations into
Payroll Tax Evasion Notice Suggests FinCEN’s New Focus
By Andrew Weiner and Jay R. Nanavati Law360 September 6, 2023 On Aug. 15, the Financial Crimes Enforcement Network within the U.S. Department of the Treasury issued Notice FIN-2023-NTC1 to advise U.S. financial institutions of the need to report payroll tax evasion and workers’ compensation
Diversity In The Tax Bar — Reflections On Lessons Learned And The Path Forward
By Stephen A. Josey, Sanessa S. Griffiths, Alyssa Pratt, and Lena Qiu Tax Notes Volume 180, September 4, 2023 Stephen Josey, Sanessa Griffiths, Alyssa Pratt, and Lena Qiu are tax practitioners who attended and reported on 9 panels conducted by the Tax System Working Group
IRS Doesn’t Have It Easy With Malta Pension Enforcement Efforts
By Caroline Ciraolo, Don Fort, and Ian Weinstock Bloomberg Tax August 28, 2023 High-net-worth US taxpayers, working with professional advisers, have transferred assets into personal retirement plans established in Malta to limit and potentially eliminate tax on distributions. These so-called Malta pension plans rely on
Diamonds in the Rough Notes: The Importance of Obtaining Informal Notes of Witness Statements
By Daniel Cady Davidson New York State Bar Association Journal August 16, 2023 For the trial attorney, familiarity with prosecution witnesses’ statements is fundamental to effective trial preparation. A recent federal health care fraud case in Texas (U.S. v. Swiencinski) underscores just how critical it
