By: Megan L. Brackney Journal of Passthrough Entities May – June 2018 Edition The Bipartisan Budget Act of 2015 (the “BBA”) made substantial changes to the audit procedures for passthrough entities. The BBA repealed the prior rules for partnership audits and replaced them with a centralized
By: Sharon L. McCarthy The CPA Journal May 2018 Edition IRS Notice 2014-21, issued on March 25, 2014, made it clear that the IRS would treat virtual currencies that can be converted into traditional currency as property for federal income tax purposes (Notice 2014-21). This means that
By Henry Stow Lovejoy CPA Journal April 2018 Edition The Internal Revenue Code (IRC) imposes penalties on understatements of tax as a way to encourage voluntary compliance and deter noncompliant behavior. Generally, the revenue agent examining a return will be one who proposes a penalty. Revenue
By Caroline Rule The Tax Lawyer In 1976, in Fisher v. United States, the Supreme Court first recognized the “act of production privilege” as being a necessary component of the Fifth Amendment’s privilege against self-incrimination. A grand jury subpoena or Service summons does not violate the Fifth
By Ian Weinstock The CPA Journal March 2018 Edition When advising taxpayers or preparing returns, brightline rules are generally the easiest to explain and to handle. In contrast, tax outcomes that depend on facts and circumstances are inherently more difficult to evaluate. It is therefore a relief
