The contours of various privileges (attorney-client, attorney work product, spousal, etc.) vary from one jurisdiction to another domestically from whether each privilege exists to who holds (or “owns”) the privilege to how it is waived or preserved. Putting those issues into cross-border transactions and negotiations
The IRS can fill out a substitute return for you—and it usually isn’t accurate. And a lot of penalties and interest will accrue. Even if you don’t go to jail, blowing off the Internal Revenue Service is a really bad idea. Take Larry Cecil Cabelka
By: Claude M. Millman The CPA Journal April 2019 Edition Government contracting is big business. More than 4 million contractors serve the U.S. government, and they collectively receive more than $500 billion per year. While many people think of those federal contracts when they refer to
By: Michael Sardar Tax Stringer April 2019 Edition Download Publication On March 13, 2018, the IRS announced that it would end its long-running Offshore Voluntary Disclosure Program (“OVDP”) on September 28, 2018. With the closure of one of the IRS’s most successful compliance enforcement programs, practitioners
Caroline Rule, as Counsel to the New York Council of Defense Lawyers, authored an Amicus Curiae brief in the New York Court of Appeals in regards to the case People v. Neulander in which the prosecution is appealing the Appellate Division, Fourth Department’s grant of a new trial to Mr. Neulander
By Sidney Kess and James R. Grimaldi The CPA Journal February 2019 The Tax Cuts and Jobs Act of 2017 (TCJA) contains both positive and negative news for Roth IRAs. Sidney Kess and James R. Grimaldi, in their article titled “New Risks and Potential Rewards
By: Ian Weinstock The CPA Journal March 2019 Edition The Treasury Department’s Financial Crimes Enforcement Network (FinCEN) Form 114, the Report of Foreign Bank and Financial Accounts—colloquially known as FBAR— has become famous due to the huge potential penalties imposed on taxpayers whose failure to file
By: Bryan C. Skarlatos and Stephen A. Josey Journal of Tax Practice & Procedure February – March 2019 Edition Tax law is so complicated that nearly everyone makes a mistake sooner or later. What should a taxpayer do when he or she learns of a mistake on a
By Sidney Kess, James A.J. Revels, James R. Grimaldi, and Thomas K. Lauletta The CPA Journal February 2019 Despite the best of intentions when couples say, “I do,” more than a few will find themselves eventually saying, “I don’t.” Aside from the emotional issues involved in
By Sidney Kess, James A.J. Revels, James R. Grimaldi, and Thomas K. Lauletta The CPA Journal February 2019 The National Center for Health Statistics reports that more than 2.1 million couples get married in the United States each year. Few probably give any thought to the
