By Megan L. Brackney Journal of Passthrough Entities January – February 2017 Edition Under the new Bipartisan Budget Act of 2015 (the “BBA”), there are significant changes to the partnership audit rules. Like TEFRA, the BBA requires partnership-level resolution of partnership income, gain, loss, deduction, and
By Juliet L. Fink The CPA Journal January 2017 Edition Although the attorney-client privilege has long been recognized under common law, there is no corresponding taxpayer-accountant privilege [other than a limited privilege for “tax advice” in some non-criminal matters under Internal Revenue Code (IRC) section 7525]. Criminal
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
