The Bipartisan Budget Act of 2015, which President Obama signed into law on November, 2015, repealed the complex and much-criticized TEFRA partnership entity-level audit rules, including the electing large partnership rules. On December 18, 2015, Congress passed, and President Obama signed into law, the Protecting
By Michael Sardar The CPA Journal July 2016 Edition It is not often in life that one is able to hit pause, rewind, and redo something that has already happened. To many taxpayers’ surprise, however, taxes are just one such area. Knowing the various options for
Thank you for attending the presentation, “How to Determine the Right Path Forward for Taxpayers with Foreign Asset Non-Compliance” by Michael Sardar For future reference please feel free to access the course materials on this web page to review or save. View or download course
By Brian P. Ketcham The CPA Journal June 2016 Edition Most CPAs are by now familiar with the IRS’s heavily publicized Offshore Voluntary Disclosure Program (OVDP), which allows taxpayers with previously undeclared foreign assets to file amended tax returns and delinquent information returns in exchange for
By Megan L. Brackney Journal of Passthrough Entities May-June 2016 Edition It is the IRS’s prerogative to change its mind. The IRS can conclude the audit of one tax year with no change and then make adjustments in a later tax year on the exact same
By Henry Stow Lovejoy The CPA Journal April 2016 Edition The “trust fund recovery penalty” can impose sizeable liabilities on officers and other employees of financially struggling or failed companies that fail to pay withholding or employment taxes. Individuals facing this penalty will often claim that
By Sidney Kess, James R. Grimaldi, and James A.J. Revels The CPA Journal March 2016 More than 2.1 million couples get married in the U.S. each year according to the National Center for Health Statistics. Few probably give any thought to the tax implications of their
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By Megan L. Brackney American Bar Association Tax Times Volume 35, No. 2 – February 2016 Although section 6501(c)(8) has been in the Code for several years, many tax practitioners remain unaware of this exception to the general three-year statute of limitations for assessment of tax
