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
By Brian P. Ketcham The Champion August 13, 2013 On June 28, 2013, the House Oversight and Government Reform Committee (the committee) passed a resolution declaring that IRS official Lois Lerner waived her Fifth Amendment rights when she appeared at a hearing before the committee on
By Caroline Rule BNA Tax Management Portfolio No. 623-3rd July 26, 2013 Tax Management Portfolio, IRS Procedures: Examinations and Appeals, No. 623-3rd, describes and discusses the law applicable to, and the policies and procedures followed by, the IRS in the examination of tax returns and administrative
By Megan L. Brackney & Joseph Septimus WG&L Journal of International Taxation July 01, 2013 The Regulations provide that the IRS may waive the filing deadline and, therefore, allow a foreign corporation that missed a deadline to use its deductions and credits if the corporation “acted reasonably
By Robert S. Fink and Wilda Lin Journal of Tax Practice & Procedure June – July 2013 Edition Robert S. Fink and Wilda Lin examine the IRS Issue Management Team’s International Individual Compliance (IIC) Group. The purpose of the IIC is to scrutinize foreign athletes and entertainers
By Robert S. Fink and Wilda Lin NYSBA Entertainment, Arts and Sports Law Journal Summer 2013 Edition, Vol. 24, No. 2 June 01, 2013 Boxing fans who were looking forward to Manny Pacquaio’ s fifth fight against Juan Manuel Marquez did not see it live in Las Vegas.
By Brian P. Ketcham WG&L Journal of Taxation May 2013 Edition An unexpected new development casts doubt about the future success of the Service’s major initiative in the campaign against hidden offshore accounts. Even more distressing are the implications for taxpayers in general about trusting IRS
By Jay R. Nanavati Bloomberg BNA Daily Tax Report November 12, 2012 Have you ever been surprised by Facebook or Linkedln’s ability to suggest people to whom you may be connected, when even you had forgotten how you were connected to those people? Perhaps the
