Caroline D. Ciraolo was quoted in a recent Tax Notes article entitled “Panamanian Summons Seen as Better Path to Law Firm Client Info,” published on August 11, 2021. The article addresses the John Doe summons authorized on July 15, 2021 to obtain information from third parties – shipping services and
Megan L. Brackney was quoted in a recent Tax Notes article entitled “What’s Reasonable for Late-Filed Foreign Information Returns?,” published on June 7, 2021. Brackney discusses the IRS’ practice of automatically assessing penalties on taxpayers who file late international information returns. The article notes: “It’s incredibly frustrating,” said Megan L.
By Bryan C. Skarlatos and Caroline Rule Journal of the American Academy of Matrimonial Lawyers Volume 33 Issue 2 (2021) When it comes to unreported foreign bank accounts, there is good news and bad news. The good news is that a previously unreported foreign bank account can dramatically increase the
In Crandall v. Commissioner (available here), in a win for taxpayers who have gone through the IRS’s offshore voluntary disclosure program (OVDP), the United States Tax Court held that the IRS was bound by the terms of a closing agreement and could not assert a deficiency (or penalty) greater than
By Dan Davidson and Destiny Reese PLI Chronicle March 2021 Issue Over 70% of federal tax filings in 2019—including almost 90% of individual income tax returns—were filed electronically. Yet, as tax practitioners know, many federal tax forms continue to require “wet” signatures. Even before the COVID-19 pandemic, there were calls for
Caroline D. Ciraolo was quoted in a recent Tax Notes article entitled “Practitioners Fear Pandemic’s Impact on Voluntary Disclosures,” published on March 25, 2021. The article focuses on discussion from a recent panel hosted by the District of Columbia Bar Taxation Community entitled “IRS Undeterred: An Update on Criminal Tax
By Usman Mohammad The CPA Journal August 2020 Edition Because U.S. taxpayers are required to report and pay taxes on their worldwide income, the U.S. government has fought to compel taxpayers to report their interests in overseas bank accounts. In the 1970s, the FBAR (Report of Foreign Bank and Financial Accounts) was created as part of
