By: Michael Sardar Tax Stringer April 2019 Edition Download Publication On March 13, 2018, the IRS announced that it would end its long-running Offshore Voluntary Disclosure Program (“OVDP”) on September 28, 2018. With the closure of one of the IRS’s most successful compliance enforcement programs, practitioners were anxious for the IRS
By: Bryan C. Skarlatos & Michael Sardar June – July 2018 Edition Journal of Tax Practice & Procedure Imagine a situation in which Congress passed a statute establishing civil penalties for certain conduct, including the maximum penalty that may be imposed for such conduct, and delegated enforcement of the statute to a federal
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 Michael Sardar The CPA Journal July 2016 Edition It is not often in life that one is able to hit pause, rewind, and redo something that has already happened. To many taxpayers’ surprise, however, taxes are just one such area. Knowing the various options for correcting an error on a
