Caroline Rule’s article, “United States v. Greenfield: A Triumph of the Fifth Amendment’s Act of Production Privilege; or Confirmation that the Privilege Can Be Entirely Abrogated by Any Act of Congress, or Even by a Treasury Regulation?” published in The Tax Lawyer, Winter 2018 (71:2),
By Christopher M. Ferguson NYSSCPA Tax Stringer April 1, 2020 On Sep. 28, 2018, the IRS’s Offshore Voluntary Disclosure Program (OVDP) came to an end; however, offshore tax and reporting noncompliance persists in today’s increasingly global economy. Tax advisors are still helping clients who have been—or
Caroline Rule’s article, “United States v. Greenfield: A Triumph of the Fifth Amendment’s Act of Production Privilege; or Confirmation that the Privilege Can Be Entirely Abrogated by Any Act of Congress, or Even by a Treasury Regulation?” published in The Tax Lawyer, Winter 2018 (71:2),
On March 27, 2020, President Trump signed into law the Coronavirus Aid, Relief, and Economic Security Act (“CARES Act”), which includes tax provisions intended to provide an economic stimulus to both businesses and individuals. The stated policy of the new legislation is to increase cash
By Caroline Rule and Bob Fink Law 360 Twenty years ago, we put forward what was then a novel concept — that the IRS and the U.S. Department of Justice were misusing the tax code to make their jobs easier. Our topic was the misuse of a statute that, we contended, was
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
