By: Megan L. Brackney The CPA Journal July 2018 Edition In January 2018, the IRS published procedures to begin enforcement of Internal Revenue Code (IRC) section 7345, which requires the State Department to deny the application for, or revoke the passport of, any individual whom the IRS certifies as having a
By: Megan L. Brackney Journal of Passthrough Entities May – June 2018 Edition The Bipartisan Budget Act of 2015 (the “BBA”) made substantial changes to the audit procedures for passthrough entities. The BBA repealed the prior rules for partnership audits and replaced them with a centralized regime that, in general, assesses
By Megan L. Brackney Law360 January 2018 The U.S. Treasury Department recently issued an interim rule to improve the Internal Revenue Service’s ability to identify contractors who have delinquent federal tax liabilities. Contractors should review their filing histories and recent returns to make sure they are up-to-date, says Megan Brackney of
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,
