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
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By Megan L. Brackney Journal of Passthrough Entities January – February 2014 Edition February 01, 2014 The reporting requirements for loss transactions can be confusing, particularly when dealing with passthrough entities, where individual partners or members may have different reporting requirements and the reporting of the
By Bryan C. Skarlatos Journal of Tax Practice & Procedure January 01, 2014 The normal statute of limitations is three years from the date the return is filed. That is how long the IRS has to challenge the accuracy of the return and assess a
By Caroline D. Ciraolo Financier Worldwide November 2013 THE UNITED STATES STRIKES AGAIN – THE NEW SWISS BANK PROGRAM The United States has taken another giant leap forward in its aggressive pursuit of individuals and entities who attempt to evade, or help others evade, US
By Megan L. Brackney Journal of Passthrough Entities September 01, 2013 The tax matters partner (“TMP”) of a TEFRA1 partnership has important duties where there is an IRS audit or controversy. One question that TMPs ask is whether a failure (or a perceived failure) to perform
By Brian P. Ketcham The Champion August 13, 2013 On June 28, 2013, the House Oversight and Government Reform Committee (the committee) passed a resolution declaring that IRS official Lois Lerner waived her Fifth Amendment rights when she appeared at a hearing before the committee on
By Megan L. Brackney & Joseph Septimus WG&L Journal of International Taxation July 01, 2013 The Regulations provide that the IRS may waive the filing deadline and, therefore, allow a foreign corporation that missed a deadline to use its deductions and credits if the corporation “acted reasonably
By Robert S. Fink and Wilda Lin Journal of Tax Practice & Procedure June – July 2013 Edition Robert S. Fink and Wilda Lin examine the IRS Issue Management Team’s International Individual Compliance (IIC) Group. The purpose of the IIC is to scrutinize foreign athletes and entertainers
By Robert S. Fink and Wilda Lin NYSBA Entertainment, Arts and Sports Law Journal Summer 2013 Edition, Vol. 24, No. 2 June 01, 2013 Boxing fans who were looking forward to Manny Pacquaio’ s fifth fight against Juan Manuel Marquez did not see it live in Las Vegas.
