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?
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
U.S. Tax Residency: Some Black-and-white Rules, Some Gray
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
First Look at the Tax Cuts and Jobs Act of 2017: Impact on Estates and Trusts
Planning for Collectibles
Tax Cuts And Jobs Act Of 2017 Introduces Major Reforms To The International Taxation Of U.S. Corporations
By Jerald David August Reprinted From The Winter 2018 Issue Of ALI-CLE’s The Practical Tax Lawyer Winter 2018 Edition On December 22, 2017, President Trump signed into law the Tax Cuts and Jobs Act (“TCJA”) of 2017, P.L. 115-97, which introduced a set of tax cuts and
Pros And Cons Of Voluntarily Disclosing Past Wrongs
By Wendy Abkin, George Abney, and Caroline D. Ciraolo Tax Executive Institute February 2018 TO DISCLOSE OR NOT TO DISCLOSE, THAT IS THE QUESTION Hamlet’s thoughts weighed heavily upon him. Should he suffer the slings and arrows of outrageous fortune, or take arms against a sea of
First Look at the Tax Cuts and Jobs Act of 2017: Impact on Investors
Understanding New IRS Rule On Contractor Tax Compliance
By Megan L. Brackney Law360 January 2018 The U.S. Treasury Department recently issued an interim rule to improve the Internal Revenue Service’s ability to identify contractors who have delinquent federal tax liabilities. Contractors should review their filing histories and recent returns to make sure they are
Tax Act First Look: The Complex New World Of The Qualified Business Deduction Rule
By Jerald David August The CPA Journal January 2018 Edition IMPLICATIONS FOR PARTNERSHIPS, S CORPORATIONS, AND SOLE PROPRIETORSHIPS President Trump signed the Tax Cuts and Jobs Act (TCJA), H.R. 1, into law on December 22, 2017. The law was passed by Congress two days earlier, on