First Look at the Tax Cuts and Jobs Act of 2017: Impact on Individuals
IRS Form 3520, Penalties, And Whether To Make A Protective Filing
By Caroline Rule The CPA Journal December 2017 Edition Whether a taxpayer is required to file IRS Form 3520, Annual Return To Report Transactions With Foreign Trusts and Receipt of Certain Foreign Gifts, is frequently unclear, yet penalties for a failure to file can be severe.
Planning for Charitable Giving by High-Income Taxpayers
The Equifax Data Breach: What CPAs and Firms Need to Know Now
Lifetime Planning with Life Insurance
Helping Business Owners Understand Valuation Approaches
Statutory Maximum/Minimum Sentences And Application Of Offense Levels
By Caroline Rule ABA Section of Litigation November 2017 Edition Most federal district court judges are accustomed – even in this age of “advisory” U.S. Sentencing Guidelines (Guidelines or U.S.S.G.) – to sentencing a criminal defendant by first calculating the applicable “Offense Level,” which provides for
The Trust Fund Recovery Penalty
By Kevin M. Flynn The CPA Journal November 2017 Edition Under Internal Revenue Code (IRC) section 6672(a), an individual can be held personally liable for a penalty for the willful failure to collect, account for, and pay to the IRS the employment taxes of a business.
Choice Of Forum Matters: Tax Court And District Court Reach Different Conclusions On Same Facts Regarding Penalties
By Bryan C. Skarlatos & Henry Stow Lovejoy Journal of Tax Practice & Procedure October – November 2017 Edition Taxpayers in a dispute with the IRS have a choice of forum in which to litigate. The Tax Court provides a pre-payment judicial review while taxpayers who pay in