First Look at the Tax Cuts and Jobs Act
Written Supervisory Approval Of IRS Penalties: When Must It Be Given, And Who May Give It?
By Henry Stow Lovejoy CPA Journal April 2018 Edition The Internal Revenue Code (IRC) imposes penalties on understatements of tax as a way to encourage voluntary compliance and deter noncompliant behavior. Generally, the revenue agent examining a return will be one who proposes a penalty. Revenue
Planning for a New Child in the Family
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
First Look at the Tax Cuts and Jobs Act of 2017: Impact on Estates and Trusts
Planning for Collectibles
Tax Cuts And Jobs Act Of 2017 Introduces Major Reforms To The International Taxation Of U.S. Corporations
By Jerald David August Reprinted From The Winter 2018 Issue Of ALI-CLE’s The Practical Tax Lawyer Winter 2018 Edition On December 22, 2017, President Trump signed into law the Tax Cuts and Jobs Act (“TCJA”) of 2017, P.L. 115-97, which introduced a set of tax cuts and
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