By Brian P. Ketcham The CPA Journal June 2016 Edition Most CPAs are by now familiar with the IRS’s heavily publicized Offshore Voluntary Disclosure Program (OVDP), which allows taxpayers with previously undeclared foreign assets to file amended tax returns and delinquent information returns in exchange for
By Megan L. Brackney Journal of Passthrough Entities May-June 2016 Edition It is the IRS’s prerogative to change its mind. The IRS can conclude the audit of one tax year with no change and then make adjustments in a later tax year on the exact same
By Henry Stow Lovejoy The CPA Journal April 2016 Edition The “trust fund recovery penalty” can impose sizeable liabilities on officers and other employees of financially struggling or failed companies that fail to pay withholding or employment taxes. Individuals facing this penalty will often claim that
By Sidney Kess, James R. Grimaldi, and James A.J. Revels The CPA Journal March 2016 More than 2.1 million couples get married in the U.S. each year according to the National Center for Health Statistics. Few probably give any thought to the tax implications of their
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By Megan L. Brackney American Bar Association Tax Times Volume 35, No. 2 – February 2016 Although section 6501(c)(8) has been in the Code for several years, many tax practitioners remain unaware of this exception to the general three-year statute of limitations for assessment of tax
By Jay R. Nanavati Law360 January 6, 2016 The investigation and prosecution of tax evasion has, in the last decade, grown from a specialized subcategory of law enforcement into a first-tier policy concern for the global community. Starting with the U.S. government’s crackdown on Swiss
By Eric Smith The CPA Journal November 2015 Edition Taxpayers involved in cash businesses are frequently under the incorrect impression that they are audit-proof and free from risk of criminal liability when the income and deductions reflected on their tax returns match their business’s books and
By Juliet L. Fink The CPA Journal May 2015 Edition The IRS whistleblower program has been around since the 1800s. In December 2006, the Tax Relief and Health Care Act made fundamental changes to the IRS whistleblower awards program and the relevant section of the relevant section
