By Bryan C. Skarlatos Journal of Tax Practice & Procedure January 01, 2014 The normal statute of limitations is three years from the date the return is filed. That is how long the IRS has to challenge the accuracy of the return and assess a deficiency.1 However, the three-year statute
By Caroline D. Ciraolo Financier Worldwide November 2013 THE UNITED STATES STRIKES AGAIN – THE NEW SWISS BANK PROGRAM The United States has taken another giant leap forward in its aggressive pursuit of individuals and entities who attempt to evade, or help others evade, US tax reporting and payment obligations
By Megan L. Brackney Journal of Passthrough Entities September 01, 2013 The tax matters partner (“TMP”) of a TEFRA1 partnership has important duties where there is an IRS audit or controversy. One question that TMPs ask is whether a failure (or a perceived failure) to perform these duties will subject him
By Robert S. Fink and Wilda Lin Journal of Tax Practice & Procedure June – July 2013 Edition Robert S. Fink and Wilda Lin examine the IRS Issue Management Team’s International Individual Compliance (IIC) Group. The purpose of the IIC is to scrutinize foreign athletes and entertainers to ensure that they have
By Juliet L. Fink and Megan L. Brackney WG&L Practical Tax Strategies Journal October 2012 Edition On 9/21/11, the IRS announced a new voluntary disclosure program, the Voluntary Classification Settlement Program (VCSP) to provide an incentive for taxpayers to comply with their employment tax obligations. The VCSP is part of a larger “fresh
By Juliet L. Fink NYSSCPA, Tax Stringer January 2012 Edition, Vol. 3, No. 1 On Sept. 21, 2011, the IRS announced a new voluntary disclosure program, the Voluntary Classification Settlement Program (VCSP), to provide an incentive for taxpayers to comply with their employment tax obligations. The VCSP is part of a
