By Caroline Rule Criminal Litigation December 2016 Edition Frequently, defense counsel in criminal investigations and prosecutions – particularly in tax-related prosecutions, but also in many other complex matters – cannot provide effective assistance to his or her client without consulting a non-attorney expert or professional, such
By Eric Smith The CPA Journal December 2016 Edition The last thing on most people’s minds during a messy divorce is the tax treatment of the support payments that will eventually be made. Unfortunately, many matrimonial attorneys also fail to consider or fully detail the parties’
By Megan L. Brackney NJ Taxing Times Winter 2016 – 2017 Edition NEITHER THE INTERNAL REVENUE CODE (“I.R.C.”) nor Treasury Regulations requires taxpayers to file amended returns. However, the ethical rules of Circular 230, the NAEA, and the AICPA call for tax practitioners to advise their
By Cassandra Vogel The CPA Journal November 2016 Edition The migration of workers into and out of the United States is a fact of the modern interconnected world. Consequently, many U.S. taxpayers acquire an interest in a foreign pension plan or other deferred compensation arrangement during
By Claude M. Millman New York Nonprofit Media November 2016 Edition New York City’s Vendor Information Exchange System (VENDEX) is an annoyance for organizations dependent on city funding. While it’s tempting to treat VENDEX compliance as clerical, it warrants attention from top executives. Perfect VENDEX compliance can
By Bryan C. Skarlatos and Megan L. Brackney Journal of Tax Practice & Procedure October – November 2016 Edition Tax practitioners often give tax advice on things like how to structure an investment in a business venture, sell an asset, plan for retirement or pass wealth to the
By Caroline Rule The CPA Journal October 2016 Edition Will the Fifth Circuit Clarify the IRS’s Burden of Proof? District courts and other authorities disagree on whether the IRS must prove willfulness by a preponderance of the evidence or by clear and convincing evidence when seeking
By Megan L. Brackney Journal of Passthrough Entities September – October 2016 Edition In my last column, I discussed the IRS’s prerogative to change its mind—to approve of a tax reporting position in one year, and then assess penalties on the ground that the taxpayer was
By Kevin M. Flynn The CPA Journal September 2016 Edition Filing a claim for refund of overpaid tax invoices much more than just submitting an amended return to the IRS with an explanatory statement that more than the correct amount of tax was paid. The refund
By Jerald David August Journal of Tax Practice & Procedure August – September 2016 Edition The Bipartisan Budget Act of 2015, which President Obama signed into law on November, 2015, repealed the complex and much-criticized TEFRA partnership entity-level audit (ELA) rules, including the electing large partnership
