By: Bryan C. Skarlatos & Michael Sardar June – July 2018 Edition Journal of Tax Practice & Procedure Imagine a situation in which Congress passed a statute establishing civil penalties for certain conduct, including the maximum penalty that may be imposed for such conduct, and delegated enforcement of the statute to a federal
By: Kevin M. Flynn September 2018 The CPA Journal On November 2, 2015, Congress enacted the Bipartisan Budget Act of 2015 (BBA), which contained sweeping changes to the Internal Revenue Code’s (IRC) partnership audit, litigation, assessment, and collection procedures. The BBA repealed the partnership audit and litigation rules enacted as part
By: Megan L. Brackney The CPA Journal July 2018 Edition In January 2018, the IRS published procedures to begin enforcement of Internal Revenue Code (IRC) section 7345, which requires the State Department to deny the application for, or revoke the passport of, any individual whom the IRS certifies as having a
By: Megan L. Brackney Journal of Passthrough Entities May – June 2018 Edition The Bipartisan Budget Act of 2015 (the “BBA”) made substantial changes to the audit procedures for passthrough entities. The BBA repealed the prior rules for partnership audits and replaced them with a centralized regime that, in general, assesses
By: Sharon L. McCarthy The CPA Journal May 2018 Edition IRS Notice 2014-21, issued on March 25, 2014, made it clear that the IRS would treat virtual currencies that can be converted into traditional currency as property for federal income tax purposes (Notice 2014-21). This means that gain from the sale and
By Wendy Abkin, George Abney, and Caroline D. Ciraolo Tax Executive Institute February 2018 TO DISCLOSE OR NOT TO DISCLOSE, THAT IS THE QUESTION Hamlet’s thoughts weighed heavily upon him. Should he suffer the slings and arrows of outrageous fortune, or take arms against a sea of troubles? For the young Prince
By Megan L. Brackney Law360 January 2018 The U.S. Treasury Department recently issued an interim rule to improve the Internal Revenue Service’s ability to identify contractors who have delinquent federal tax liabilities. Contractors should review their filing histories and recent returns to make sure they are up-to-date, says Megan Brackney of
By Jerald David August The CPA Journal January 2018 Edition IMPLICATIONS FOR PARTNERSHIPS, S CORPORATIONS, AND SOLE PROPRIETORSHIPS President Trump signed the Tax Cuts and Jobs Act (TCJA), H.R. 1, into law on December 22, 2017. The law was passed by Congress two days earlier, on December 20, 2017. In general,
By Megan L. Brackney Journal of Passthrough Entities January – February 2018 Edition The Treasury Inspector General for Tax Administration (“TIGTA”) recently issued its Fiscal Year 2017 Statutory Review of Compliance with the Freedom of Information Act. TIGTA noted that in fiscal year 2016, the IRS processed 8,808 requests to the
