By Dan Davidson The CPA Journal December 2020/January 2021 Edition It is never pleasant when a client relationship ends on less than amicable terms. This is especially true when the relationship’s demise leads to litigation. A contract dispute that was recently litigated in bankruptcy court [In re Kent, 615 B.R. 171
On December 11, 2020, the Financial Crimes Enforcement Network (FinCEN) issued Notice 2020-1 (the Notice) which extends until April 15, 2022 the deadline to file Reports of Foreign Bank and Financial Accounts (FBARs) (FinCEN Form 114) for certain officers, employees, or agents of a U.S. entity who have signature or
Recent clarifications to the Delinquent International Information Return Submission Procedures (“DIIRSP”) remind taxpayers and their advisors of the need to understand the standards, case law, and administrative guidance that apply to requests to have late-filing penalties abated on the ground of reasonable cause. In June 2014, the Internal Revenue Service’s
Baltimore (December 14, 2020) — Super Lawyers has once again selected partner Caroline D. Ciraolo for inclusion on the Maryland Super Lawyers list as a “Top Rated Tax Attorney in Baltimore, MD,” this time for 2021. Ms. Ciraolo was also listed on the 2020 Maryland Super Lawyers list and was previously included on
Robert M. Russell was quoted in a Tax Notes article entitled “Transition Tax Campaign’s Focus on E&P Concerns Practitioners,” published on December 3, 2020. Russell observes that return preparers were concerned about the starting point of determining E&P, given that taxpayers may not possess the best records for past years.
By: Sidney Kess and Thomas K. Lauletta Estate Planning Review—THE JOURNAL VOLUME 46 | ISSUE 10 | OCTOBER 22, 2020 Many experts are focusing primarily on the tax issues that are likely to arise as a result of the election, such as changes in the wealth tax and estate taxes. We
By Olivia H. Renensland Law360 September 30, 2020 In the fall of 1970, future U.S. Supreme Court Justice Ruth Bader Ginsburg and her husband Martin Ginsburg decided to take on Moritz v. Commissioner, representing Charles Moritz in his appeal of a U.S. Tax Court decision that denied him a dependent care
By: Caroline Rule Journal of Tax Practice & Procedure Fall 2020 Edition This article will discuss cases after June 2019 that have followed, rejected, or partially relied on the precedents of Williams and McBride, which cases include language to the effect that, if a taxpayer signs a Form 1040 income tax
By Megan L. Brackney Tax Notes Federal September 28, 2020 In a Sept. 28, 2020 Tax Notes article entitled, “Focus on High-Net-Worth Nonfilers,” Megan Brackney examines what taxpayers who fail to file returns can expect from the IRS, and she offers strategies to avoid some of the harsher potential consequences of
