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
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
