By Kevin M. Flynn The CPA Journal September 2020 Edition Since 1969, Internal Revenue Code (IRC) section 162(f) has disallowed an ordinary and necessary business deduction in computing taxable income for any civil or criminal fine or similar penalty paid to a government or governmental entity for the violation of a
By Usman Mohammad The CPA Journal August 2020 Edition Because U.S. taxpayers are required to report and pay taxes on their worldwide income, the U.S. government has fought to compel taxpayers to report their interests in overseas bank accounts. In the 1970s, the FBAR (Report of Foreign Bank and Financial Accounts) was created as part of
By Megan L. Brackney The CPA Journal June 2020 Edition The Internal Revenue Code and the Bank Secrecy Act (BSA) require that persons engaged in a trade or business file Form 8300, Report of Cash Payments Over $10,000 Received in a Trade or Business, any time the business receives more than $10,000
By: Caroline Rule Journal of Tax Practice & Procedure Summer 2020 Edition Recent litigation has focused on the government’s new position that the $10,000 non-willful civil FBAR penalty applies per account listed on an non-willfully untimely-filed annual FBAR—a Report of Foreign Bank or Financial Accounts that must be filed by a U.S. person “who
By Usman Mohammad The ABA Tax Times Vol. 39 No. 3 – Spring 2020 Puerto Rico, American Samoa, Guam, The United States Virgin Islands, The Northern Mariana Islands—these are all United States territories or possessions. Individuals born in these territories are deemed by law to be either United States citizens or
By: Robert S. Fink LexisNexis 39th Ed. 2020 The 39th edition of “Tax Controversies: Audits, Investigations, Trials” has been published and is available on Lexis-Nexis. Authored by Kostelanetz & Fink co-founder Robert S. Fink and the attorneys of Kostelanetz & Fink, Tax Controversies is the recognized guide to all stages of tax examination,
By Megan L. Brackney Tax Notes Federal April 27, 2020 Given that combating tax fraud is a top agency priority, it is a good time to review the law and procedures related to tax fraud. In this article, Megan Brackney discusses the ways the IRS identifies and addresses fraud, the consequences
By Caroline D. Ciraolo Journal of Tax Practice and Procedure Spring 2020 Edition At the 35th Annual UCLA Extension Tax Controversy Institute, Caroline D. Ciraolo and her fellow panelists addressed international tax compliance and enforcement, including what’s old, what’s new and what we can expect going forward. “We cannot continue to operate
By Megan L. Brackney Tax Notes In this article, Brackney discusses the John Doe summons procedures and the decision partially enforcing a John Doe summons in Coinbase. She also identifies some practical considerations for taxpayers whose information may be turned over to the IRS in accordance with the summons. Full Article
By Juliet L. Fink The CPA Journal March 2020 Edition Section 7623 of the Internal Revenue Code (IRC) allows for the payment of financial awards to those who blow the whistle on individuals or corporations that have deliberately underreported or underpaid their taxes. Such awards are based on the amount ultimately
