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
By Jay R. Nanavati Law360 January 6, 2016 The investigation and prosecution of tax evasion has, in the last decade, grown from a specialized subcategory of law enforcement into a first-tier policy concern for the global community. Starting with the U.S. government’s crackdown on Swiss
By Eric Smith The CPA Journal November 2015 Edition Taxpayers involved in cash businesses are frequently under the incorrect impression that they are audit-proof and free from risk of criminal liability when the income and deductions reflected on their tax returns match their business’s books and
By Juliet L. Fink The CPA Journal May 2015 Edition The IRS whistleblower program has been around since the 1800s. In December 2006, the Tax Relief and Health Care Act made fundamental changes to the IRS whistleblower awards program and the relevant section of the relevant section
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By Megan L. Brackney Practical Tax Strategies February 01, 2014 A client calls his long-time, trusted accountant, and nervously says: “There is something I need to talk to you about. Can I come in to see you? I don’t want to talk about it over the
By Megan L. Brackney Journal of Passthrough Entities January – February 2014 Edition February 01, 2014 The reporting requirements for loss transactions can be confusing, particularly when dealing with passthrough entities, where individual partners or members may have different reporting requirements and the reporting of the
By Bryan C. Skarlatos Journal of Tax Practice & Procedure January 01, 2014 The normal statute of limitations is three years from the date the return is filed. That is how long the IRS has to challenge the accuracy of the return and assess a
By Caroline D. Ciraolo Financier Worldwide November 2013 THE UNITED STATES STRIKES AGAIN – THE NEW SWISS BANK PROGRAM The United States has taken another giant leap forward in its aggressive pursuit of individuals and entities who attempt to evade, or help others evade, US
By Megan L. Brackney Journal of Passthrough Entities September 01, 2013 The tax matters partner (“TMP”) of a TEFRA1 partnership has important duties where there is an IRS audit or controversy. One question that TMPs ask is whether a failure (or a perceived failure) to perform
