By Megan L. Brackney Tax Notes In this article, Brackney discusses the John Doe summons procedures and the decision partially enforcing a John Doe summons in Coinbase. She also identifies some practical considerations for taxpayers whose information may be turned over to the IRS in accordance with
In the event of a loss of client records or due to poor record keeping, a tax preparer may need to help his client reconstruct the records and/or make estimates. This session covered tips and ideas on how to handle such issues from tax-return preparation
On March 20, 2020, the IRS issued Notice 2020-18, which provides updated guidance on the extension of the April 15, 2020 tax return filing and payment deadlines due to the Coronavirus pandemic. On March 24, 2020, the IRS issued FAQs to answer various questions regarding Notice
In new IRS guidance, certain foreign trusts receive a significant break from information reporting and the potential refund of penalties. The IRS will now exempt eligible U.S. persons from reporting transactions with, or ownership of, certain tax-favored foreign trusts that are operated exclusively (or nearly
By Juliet L. Fink The CPA Journal March 2020 Edition Section 7623 of the Internal Revenue Code (IRC) allows for the payment of financial awards to those who blow the whistle on individuals or corporations that have deliberately underreported or underpaid their taxes. Such awards are
In a TaxNotes article entitled, “Practitioners Fault Accelerated Assessable Penalty Collection,” Megan Brackney is quoted on how “the IRS’s collections practice for assessable penalties related to foreign information returns is increasingly placing taxpayers in a bind, and practitioners are eager to provide suggestions on how
By Sharon L. McCarthy The CPA Journal March 2020 Edition Brian Nelson Booker has the dubious distinction of being the first person criminally charged by the Department of Justice (DOJ) with allegedly making false statements in connection with the IRS’s Streamlined Domestic Offshore Program (SDOP). The
City and State notes the list represents “New York’s 100 most influential lawyers . . . based on their achievements, track record and sway in political and policy matters.” The list describes Mr. Millman as a “seasoned attorney who appears regularly on lists of top lawyers” who
Megan Brackney was named by Lawline as one of the “Top Women Faculty of 2019” for a CLE program she taught entitled “Tax Procedure: IRS Methods of Obtaining Information From and About Taxpayers.” Lawline noted that the program “has received 500 views and counting since the
By Sidney Kess and Julie Welch The CPA Journal February 2020 With stocks at or near record levels, prudent financial planning might call for taking defensive measures. One strategy could be to focus on dividend-paying stocks. Companies that make enough money to distribute some to shareholders
