Tax Professional Practice

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Supreme Court of Canada to Decide if a Lawyer Subject to Enforcement Proceedings can Claim Solicitor-Client Privilege

The Supreme Court of Canada recently granted leave to appeal in Minister of National Revenue v Duncan Thompson, 2013 FCA 197, which touches on the issue of whether a lawyer subject to enforcement proceedings can claim...more

Tax Law Blog: Electronic Signatures, What's Next?

While more and more transactions are eliminating paper and becoming completely electronic, I think we all assumed certain documents would still need to be signed on paper. For example, real estate documents, tax documents,...more

Structured Settlement Planning for Trial Attorneys: The Benefits of Using Qualified Settlement Funds and Private Placement...

Overview - Trial attorneys are extremely vulnerable to a tax landscape that is becoming hostile territory. The result of the American Taxpayer Relief Act of 2013 (ATRA) is that earned income is taxed at substantially...more

A Modest Proposal: The Discount and Refund-or-Donate Policy

Originally published in Taxation of Exempts - March/April 2013. Despite all of the jokes to the contrary, lawyers as a professional group are remarkably charitable. Unlike plumbers, doctors, electricians, pharmacists,...more

Income Tax Reduction and Deferral Strategies for Trial Attorney Contingency Fee Income: Part 1—Structured Settlement Annuities...

Originally published in ABA Section of Taxation NewsQuarterly in the Summer of 2012. Overview - Structured settlement annuities (SSA) have been recognized by federal law since 1983. The original use of these...more

IRS Form 4506-T Electronic Signature Requirements

This document includes the requirements for the suggested framework which all IVES Participants must adhere to in order to participate using electronic signatures for IRS Forms 4506-T or 4506T-EZ....more

Should you Opt-Out of the Voluntary Disclosure Program? [Video]

When is it right to op-out of the voluntary disclosure program, knowing when to stay in and when to get out could be the difference of saving a massive amount of money and staying out of jail. Talk to a professional who can...more

Weekly Brief: CFPB, Legal Fees & Hashtag Hijackers [Video]

Oct. 18 (Bloomberg Law) -- Bloomberg Law's Lee Pacchia runs through the week's most important legal news. The Consumer Finance Protection Bureau is considering a plan to grant unprecedented legal immunity to mortgage lenders....more

Here is Something to Whistle About!- Reflections on the UBS Whistleblower - Tax Reduction and Deferral Strategies for Trial...

Over the last few weeks I have been diligently outlining tax planning strategies for trial attorneys with contingent fee income. These strategies have ranged from structured settlement arrangements using private placement...more

IRS Set To Ease Practitioner Rules

Almost every email I send out to anyone has this at the end: CHUCK Charles (Chuck) Rubin, Esq. Gutter Chaves Josepher Rubin Forman Fleisher P.A. Board Certified in Taxation PRINCIPAL PRACTICE AREAS....more

Tax Reduction and Deferral Strategies for Trial Attorneys – Part 5 : Structured Settlement Life Insurance – A Tax-Free...

In Part 5, I focus on the utility of the QSF from an investment funding perspective to illustrate how private placement life insurance can be used in a split dollar life insurance funding format in order to to create a...more

Tax Reduction and Deferral Strategies for Trial Attorneys – Part 4: The Trial Attorney’s Pension Plan

Part I of this series focused on tax reduction and deferral strategies for trial attorneys with contingent fee income using private placement variable deferred annuities in lieu of fixed annuities for structured settlement...more

Trial attorney - Tax Planning Using PPLI and CLATs (Supplemental Presentation)

Part I of this series focused on tax reduction and deferral strategies for trial attorneys with contingent fee income using private placement variable deferred annuities in lieu of fixed annuities for structured...more

Tax Reduction and Deferral Strategies for Trial Attorneys – Part 3

Part I of this series focused on tax reduction and deferral strategies for trial attorneys with contingent fee income using private placement variable deferred annuities in lieu of fixed annuities for structured settlement...more

Tax Reduction and Deferral Strategies for Trial Attorneys – Part 2

Part I of this series focusing on tax reduction and deferral strategies for trial attorneys with contingent fee income examined the use of private placement variable deferred annuities in lieu of fixed annuities for...more

Tax Reduction and Deferral Strategies for Trial Attorneys - Part 1

Trial attorneys are extremely vulnerable to changing tax landscape which is quickly becoming hostile territory. As the Bush tax cuts are due to expire at the end of December 2012, the tax increases will further erode trial...more

How to Pick a Worthy Charity

Clients frequently ask for recommendations for their charitable giving. In some cases, donors have a clear idea of the area of activity to support but do not know how to identify the most worthy charities. Other clients have...more

Income Tax Reduction and Deferral Strategies for Trial Attorney Contingency Fee Income: Part 1—Structured Settlement Annuities...

Originally published in ABA Section of Taxation News Quarterly - Summer 2012. Overview - Structured settlement annuities (SSA) have been recognized by federal law since 1983. The original use of these arrangements was...more

Foreign Gift Assets on IRS Radar [Video]

Foreign Gift Assets in off shore accounts used to be safe from the IRS. Not anymore, with the growing cooperation of nations around the world U.S. citizens foreign account information will sooner or later (within 2 years) end...more

Foreign Asset Disclosure Program [Video]

Foreign Asset Disclosure and the Voluntary Program. This is the program that anybody with clients who have assets off shore should be aware of. Why? Because it's an opportunity for your clients to come forward and...more

Gibraltar - You may be missing out if you do not consider this jurisdiction

This is an extensive article which sets out to summarise those areas of Gibraltar legislation that are most pertinent to potential foreign investors in the jurisdiction. The reader should get a good flavour of the...more

Atlantic Electronics -v- HM Revenue & Customs

Fairness in Justice – Fighting one taxpayer by using the others taxes!.

The Chamber President, The Hon Mr. Justice Warren in the cases of HMRC –v- Atlantic Electronics held AN APPEAL BY HMRC TO disapply Rule 10 of the 2009 Rules is DISMISSED! “The right to opt out from Costs is a recognition of...more

VAT windfall for UK solicitors?

Solicitors can make back claims to recover 100% VAT bad debt relief where insured clients failed to pay the VAT element of the bill...more

Taxing Times: HMRC set to fine firms £3,000 for "assisting in preparation of incorrect SDLT returns"

Her Majesty’s Revenue & Customs (“HMRC”) has announced that it intends to start imposing the maximum penalty of £3,000 in respect of online and paper SDLT returns under section 96 of the Finance Act...more

Owe Back Taxes? Beware of Hiring "Quick Fix" Firms

If you are struggling to pay your taxes, the last thing you need is to lose more money to a bogus scheme, and it is important that you be alert to the dangers of a quick fix to resolve any big tax bills....more

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