By Megan L. Brackney Journal of Passthrough Entities May – June 2017 Edition “John Doe” summonses have been in the news again.[1] On January 24, 2017, a federal district court unsealed an order authorizing the Department of Justice (DOJ) to serve a John Doe summons upon
By Henry Stow Lovejoy Original Publication: The CPA Journal, April 2017 Edition Re-Published & Updated Publication: The Practical Tax Lawyer, Summer 2017 Edition The Internal Revenue Code (IRC) requires the filing of a number of different information returns with respect to foreign entities or transactions. These “international information
By Claude M. Millman New York Nonprofit Media March 2017 Edition Nonprofits receiving contract awards from New York City or the state should carefully monitor President Donald Trump’s budget policies for potential retroactive effects on pre-existing contracts. New York City Comptroller Scott Stringer recently reported that while just
By Megan L. Brackney Journal of Passthrough Entities January – February 2017 Edition Under the new Bipartisan Budget Act of 2015 (the “BBA”), there are significant changes to the partnership audit rules. Like TEFRA, the BBA requires partnership-level resolution of partnership income, gain, loss, deduction, and
By Juliet L. Fink The CPA Journal January 2017 Edition Although the attorney-client privilege has long been recognized under common law, there is no corresponding taxpayer-accountant privilege [other than a limited privilege for “tax advice” in some non-criminal matters under Internal Revenue Code (IRC) section 7525]. Criminal
By Caroline Rule Criminal Litigation December 2016 Edition Frequently, defense counsel in criminal investigations and prosecutions – particularly in tax-related prosecutions, but also in many other complex matters – cannot provide effective assistance to his or her client without consulting a non-attorney expert or professional, such
By Eric Smith The CPA Journal December 2016 Edition The last thing on most people’s minds during a messy divorce is the tax treatment of the support payments that will eventually be made. Unfortunately, many matrimonial attorneys also fail to consider or fully detail the parties’
By Megan L. Brackney NJ Taxing Times Winter 2016 – 2017 Edition NEITHER THE INTERNAL REVENUE CODE (“I.R.C.”) nor Treasury Regulations requires taxpayers to file amended returns. However, the ethical rules of Circular 230, the NAEA, and the AICPA call for tax practitioners to advise their
By Cassandra Vogel The CPA Journal November 2016 Edition The migration of workers into and out of the United States is a fact of the modern interconnected world. Consequently, many U.S. taxpayers acquire an interest in a foreign pension plan or other deferred compensation arrangement during
