By: Usman Mohammad The CPA Journal January 2019 Edition On November 20, 2018, the IRS published an Interim Guidance Memo concerning voluntary disclosures, captioned “Updated Voluntary Disclosure Practice” (http://bit.ly/2UHHdLm). The memo sets forth the IRS’s current policy for handling voluntary disclosures (both offshore and domestic) following the closing of the IRS’s
By: Jay Nanavati The CPA Journal December 2018 Edition In modernizing the tax whistleblower statute over the last 12 years, Congress has finally created a simple and enforceable entitlement to substantial compensation for tax whistleblowers. Unfortunately, in practice, the IRS’s whistleblower program still falls short of achieving its potential for improving
By: Michael Sardar August 2018 Edition The CPA Journal On March 13, the IRS announced that it will close the Offshore Voluntary Disclosure Program (OVDP), effective September 28, 2018. In the announcement, the IRS encouraged taxpayers who need to disclose noncompliant and unreported foreign accounts and assets to come forward before
By: Sharon L. McCarthy The CPA Journal May 2018 Edition IRS Notice 2014-21, issued on March 25, 2014, made it clear that the IRS would treat virtual currencies that can be converted into traditional currency as property for federal income tax purposes (Notice 2014-21). This means that gain from the sale and
By Caroline Rule The Tax Lawyer In 1976, in Fisher v. United States, the Supreme Court first recognized the “act of production privilege” as being a necessary component of the Fifth Amendment’s privilege against self-incrimination. A grand jury subpoena or Service summons does not violate the Fifth Amendment just because documents the
By Wendy Abkin, George Abney, and Caroline D. Ciraolo Tax Executive Institute February 2018 TO DISCLOSE OR NOT TO DISCLOSE, THAT IS THE QUESTION Hamlet’s thoughts weighed heavily upon him. Should he suffer the slings and arrows of outrageous fortune, or take arms against a sea of troubles? For the young Prince
By Bryan C. Skarlatos & Henry Stow Lovejoy Journal of Tax Practice & Procedure October – November 2017 Edition Taxpayers in a dispute with the IRS have a choice of forum in which to litigate. The Tax Court provides a pre-payment judicial review while taxpayers who pay in advance can sue for refund
Op-Ed By Bryan C. Skarlatos Featured on CNBC Crypto currencies may have been around for less than a decade, but they are proliferating so quickly that our established tax and regulatory systems can’t keep up. And that could create serious tax problems for those who would join the digital currency revolution.
By Michael Sardar The CPA Journal September 2017 Edition Several years ago, the IRS started its successful takedown of secret Swiss banking with the use of a John Doe summons. 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
