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
By Megan L. Brackney The CPA Journal May 2017 Edition If it is not already on the schedule, CPAs should remember to talk to business clients about withholding on payments to nonresident aliens. Full Article
By Megan L. Brackney Journal of Passthrough Entities May – June 2017 Edition “John Doe” summonses have been in the news again.[1] On January 24, 2017, a federal district court unsealed an order authorizing the Department of Justice (DOJ) to serve a John Doe summons upon a third party to obtain
By Megan L. Brackney Journal of Passthrough Entities January – February 2017 Edition Under the new Bipartisan Budget Act of 2015 (the “BBA”), there are significant changes to the partnership audit rules. Like TEFRA, the BBA requires partnership-level resolution of partnership income, gain, loss, deduction, and credits. Unlike TEFRA, under the BBA,
By Juliet L. Fink The CPA Journal January 2017 Edition Although the attorney-client privilege has long been recognized under common law, there is no corresponding taxpayer-accountant privilege [other than a limited privilege for “tax advice” in some non-criminal matters under Internal Revenue Code (IRC) section 7525]. Criminal and civil tax cases, however,
By Megan L. Brackney NJ Taxing Times Winter 2016 – 2017 Edition NEITHER THE INTERNAL REVENUE CODE (“I.R.C.”) nor Treasury Regulations requires taxpayers to file amended returns. However, the ethical rules of Circular 230, the NAEA, and the AICPA call for tax practitioners to advise their clients about errors or omissions
By Bryan C. Skarlatos and Megan L. Brackney Journal of Tax Practice & Procedure October – November 2016 Edition Tax practitioners often give tax advice on things like how to structure an investment in a business venture, sell an asset, plan for retirement or pass wealth to the next generation. Sometimes a practitioner’s
