When Client Relationships Don’t End Amicably
By Dan Davidson The CPA Journal December 2020/January 2021 Edition It is never pleasant when a client relationship ends on less than amicable terms. This is especially true when the relationship’s demise leads to litigation. A contract dispute that was recently litigated in bankruptcy court [In
Tax Treatment Of Liquidations Of Partnership Interests
By Eric Smith The CPA Journal December 2020/January 2021 Edition The liquidation of a partner’s entire partnership interest can take various forms, including payment made by the partnership to the retiring partner in complete redemption of the partner’s interest or a sale of such interest to
Mitigating IRS Cryptocurrency Enforcement Risk in 2021
The Impact of the IRS’s Clarification of the DIIRSP
Recent clarifications to the Delinquent International Information Return Submission Procedures (“DIIRSP”) remind taxpayers and their advisors of the need to understand the standards, case law, and administrative guidance that apply to requests to have late-filing penalties abated on the ground of reasonable cause. In June
More Bankruptcies, More Opportunities and Challenges for CPAs
By: Sidney Kess, Alan Gassman, and Aaron Slavutin The CPA Journal October/November 2020 From name-brand corporations like JCPenney and Neiman Marcus to small and mid-sized companies, businesses of all sizes are responding to pandemic-related lockdowns by seeking refuge in bankruptcy. Legal services provider Epiq has reported
Beyond Tax: Contested Election, Trade War, and the Post-COVID World
By: Sidney Kess and Thomas K. Lauletta Estate Planning Review—THE JOURNAL VOLUME 46 | ISSUE 10 | OCTOBER 22, 2020 Many experts are focusing primarily on the tax issues that are likely to arise as a result of the election, such as changes in the wealth
Indigent Access To Justice Debated In Luxury Condo Appeal
By Claude M. Millman, with Russell A.S. Wirth New York Law Journal October 1, 2020 The New York State Court of Appeals is poised to hear oral argument in a case about the financing of a luxury, residential tower on Sutton Place in Manhattan—but some not-for-profits are
A Tax Case Key To Justice Ginsburg’s Equal Protection Fight
By Olivia H. Renensland Law360 September 30, 2020 In the fall of 1970, future U.S. Supreme Court Justice Ruth Bader Ginsburg and her husband Martin Ginsburg decided to take on Moritz v. Commissioner, representing Charles Moritz in his appeal of a U.S. Tax Court decision that
An Update On Civil FBAR Penalties: Decisions Since June 2019 Citing Williams And Mcbride In Discussing The Willful Civil FBAR Penalty
By: Caroline Rule Journal of Tax Practice & Procedure Fall 2020 Edition This article will discuss cases after June 2019 that have followed, rejected, or partially relied on the precedents of Williams and McBride, which cases include language to the effect that, if a taxpayer signs