Skip links

Blog

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?

By Caroline Rule The Tax Lawyer In 1976, in Fisher v. United States, the Supreme Court first recognized the “act of production privilege” as being a necessary component of the Fifth Amendment’s privilege against self-incrimination. A grand jury subpoena or Service summons does not violate the Fifth

U.S. Tax Residency: Some Black-and-white Rules, Some Gray

By Ian Weinstock The CPA Journal March 2018 Edition When advising taxpayers or preparing returns, brightline rules are generally the easiest to explain and to handle. In contrast, tax outcomes that depend on facts and circumstances are inherently more difficult to evaluate. It is therefore a relief

Planning for Collectibles

By Sidney Kess, James R. Grimaldi, and James A.J. Revels CPA Journal February 2018 Issue Collectibles, such as art, wine, jewelry, and coins and stamps, have long been important assets to individuals, particularly high-net-worth individuals. Art collectors say that the emotional value of buying is their

Pros And Cons Of Voluntarily Disclosing Past Wrongs

By Wendy Abkin, George Abney, and Caroline D. Ciraolo Tax Executive Institute February 2018 TO DISCLOSE OR NOT TO DISCLOSE, THAT IS THE QUESTION Hamlet’s thoughts weighed heavily upon him. Should he suffer the slings and arrows of outrageous fortune, or take arms against a sea of

Understanding New IRS Rule On Contractor Tax Compliance

By Megan L. Brackney Law360 January 2018 The U.S. Treasury Department recently issued an interim rule to improve the Internal Revenue Service’s ability to identify contractors who have delinquent federal tax liabilities. Contractors should review their filing histories and recent returns to make sure they are