By Caroline Rule The CPA Journal December 2017 Edition Whether a taxpayer is required to file IRS Form 3520, Annual Return To Report Transactions With Foreign Trusts and Receipt of Certain Foreign Gifts, is frequently unclear, yet penalties for a failure to file can be severe. As a result, although there
By Kevin M. Flynn The CPA Journal November 2017 Edition Under Internal Revenue Code (IRC) section 6672(a), an individual can be held personally liable for a penalty for the willful failure to collect, account for, and pay to the IRS the employment taxes of a business. Full Article
By Bryan C. Skarlatos & Henry Stow Lovejoy Journal of Tax Practice & Procedure October – November 2017 Edition Taxpayers in a dispute with the IRS have a choice of forum in which to litigate. The Tax Court provides a pre-payment judicial review while taxpayers who pay in advance can sue for refund
Op-Ed By Bryan C. Skarlatos Featured on CNBC Crypto currencies may have been around for less than a decade, but they are proliferating so quickly that our established tax and regulatory systems can’t keep up. And that could create serious tax problems for those who would join the digital currency revolution.
By Michael Sardar The CPA Journal September 2017 Edition Several years ago, the IRS started its successful takedown of secret Swiss banking with the use of a John Doe summons. Full Article
By Megan L. Brackney Journal of Taxation October 2017 Edition After a long period of inactivity, the IRS has recently released four notices identifying new reportable transactions. Full Article
By Megan L. Brackney Journal of Passthrough Entities September – October 2017 Edition If you are preparing, or advising on, the filing of amended returns or other claims for refund, one of the most important things to consider is the variance doctrine, and how it could impact your client’s ability to
By Jerald David August Corporate Taxation September 2017 Edition Although new partnership audit rules have been enacted, the TEFRA entity-level audit rules, particularly the tax manger partner rules, continue to be relevant. Full Article
By Bryan C. Skarlatos & Henry Stow Lovejoy Journal of Tax Practice & Procedure June – July 2017 Edition Taxpayers who have underpaid their taxes can avoid accuracy-related penalties under Code Sec. 6662 by demonstrating that they acted with reasonable cause and in good faith. In general, the most important factor in determining
By Sharon L. McCarthy The CPA Journal July 2017 Edition Tax professionals, and also the general public, well know by now that U.S. taxpayers are required to report foreign financial accounts to the government. Full Article
