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
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
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
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
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
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
By Megan L. Brackney Tax Notes Federal September 28, 2020 In a Sept. 28, 2020 Tax Notes article entitled, “Focus on High-Net-Worth Nonfilers,” Megan Brackney examines what taxpayers who fail to file returns can expect from the IRS, and she offers strategies to avoid some of
By Kevin M. Flynn The CPA Journal September 2020 Edition Since 1969, Internal Revenue Code (IRC) section 162(f) has disallowed an ordinary and necessary business deduction in computing taxable income for any civil or criminal fine or similar penalty paid to a government or governmental entity
By Usman Mohammad The CPA Journal August 2020 Edition Because U.S. taxpayers are required to report and pay taxes on their worldwide income, the U.S. government has fought to compel taxpayers to report their interests in overseas bank accounts. In the 1970s, the FBAR (Report of Foreign Bank and Financial
