By Megan L. Brackney Journal of Passthrough Entities January – February 2018 Edition The Treasury Inspector General for Tax Administration (“TIGTA”) recently issued its Fiscal Year 2017 Statutory Review of Compliance with the Freedom of Information Act. TIGTA noted that in fiscal year 2016, the IRS processed 8,808 requests to the
By Megan L. Brackney Journal of Taxation October 2017 Edition After a long period of inactivity, the IRS has recently released four notices identifying new reportable transactions. Full Article
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 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 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
By Megan L. Brackney Journal of Passthrough Entities September – October 2016 Edition In my last column, I discussed the IRS’s prerogative to change its mind—to approve of a tax reporting position in one year, and then assess penalties on the ground that the taxpayer was negligent or did not have
