Tax Returns

News & Analysis as of

Should You Consider Making a Domestic Voluntary Disclosure?

Voluntary Disclosures take two forms, Offshore and Domestic. There has been a great deal of attention paid to Offshore Voluntary Disclosure Programs, but little attention has been paid to the Domestic program....more

Minimize Your Chances in the IRS Audit Lottery

Although most people would love to win “the lottery,” that’s not always the case, such as in Shirley Jackson’s like-titled story or in the more recent Hunger Games series. Likewise, the IRS Audit Lottery is one best avoided...more

IRS Private Letter Ruling Addressing Captive Professional Corporations Could Result in Significant “Consolidated” Tax Savings

On December 19, 2014, the Internal Revenue Service published PLR 201451009, favorably ruling that a for-profit management company could include its captive professional corporation as a member of its consolidated group for...more

Legal Alert: Has New York City Added a Fourth Element for Determining a Combined Group?

A New York Tax Appeals Tribunal Administrative Law Judge (ALJ) recently determined that a federal savings and loan association was not required to include a subsidiary, which was formed as a Connecticut passive investment...more

MoFo New York Tax Insights - Volume 5, Issue 11 - November 2014

In This Issue: - Court Orders Department of Finance to Release Corporate Tax Return Records to City Comptroller - ALJ Upholds State Tax Department Policy on Personal Liability of LLC Members for Sales...more

Tax Identity Verification Letter Could Mean Fraud: A Checklist of What To Do

Did you receive a letter from the IRS (specifically LTR 5071C) or a letter from the Ohio Department of Taxation asking you to verify your identity or suggesting you may be a victim of identity theft? If so, you’re not alone....more

Three Year-End Tax Tips

If divorcing your spouse is not difficult enough, those who are not legally divorced by December 31 must begin thinking at this time of year about tax planning as “married” individuals. The issue of tax filing becomes an...more

Tax Law Blog: More 2015 Tax Numbers Released, Including Tax Brackets

I previously posted about the increase in retirement plan contribution limits for 2015. This week the IRS announced the tax brackets, personal exemption, and standard deduction amounts for tax year 2015. To be clear, the new...more

Facebook and IMs Provide Key Evidence to Prosecutors in Criminal Cases

Two recent events demonstrate how prosecutors are increasingly turning to other forms of electronic information to construct their cases. First, Francisco R. Legaspi, now 61, who had been a fugitive for the past 22 years, was...more

More Tax Lessons from Reality Stars on What Not to Do, Plus Lionel Messi

We discussed last week the surprise when a highly visible reality star is charged with or convicted of tax evasion or other financial crimes (see last week’s post here about The Situation and referencing Richard Hatch). This...more

“The Situtation” for Sorrentinos Getting Worse With Social Media

As many have heard recently, Michael Sorrentino (of MTV’s “Jersey Shore” fame) and his brother Marc were indicted for tax crimes in New Jersey and made their initial appearance in court last week. At this point, no one...more

Nevada Supreme Court Upholds Fraud Verdict Against The California Franchise Tax Board

The Franchise Tax Board’s Shande - This is case that has been more than two decades in the making. It began in the 1990s when inventor Gilbert Hyatt filed a California tax return showing that he relocated from...more

State Tax Implications of Fourth Circuit Court of Appeals Decision Rejecting Virginia’s Same-Sex Marriage Ban

On Monday, the Court of Appeals for the Fourth Circuit invalidated Virginia’s prohibition on same-sex marriages. Bostic v. Schaefer, Docket No. 14-1167 (4th Cir. July 28, 2014). The Fourth Circuit includes Virginia, Maryland,...more

The Gambler Breaks Even: Tax Court Orders Indiana Department Of Revenue To Answer Discovery Requests But Denies Taxpayer’s Second...

The Tax Court does not often address discovery issues in published decisions and orders. In this case, Popovich v. Indiana Department of State Revenue, Cause No. 49T10-1010-TA-53 (April 24, 2014 and June 4, 2014), the Court...more

"Latest Swiss Cross-Border Tax Investigation Reflects Wider US Enforcement Agenda"

Authorities in the U.S. continue to crack down on foreign financial institutions that have allegedly aided U.S. taxpayers in evading their tax obligations. On May 19, 2014, Credit Suisse AG pled guilty to conspiracy to aid...more

PA Overturns Same-Sex Marriage Ban – Employers Face Significant Changes in Employee Benefits and Leave Administration

As a result of the same-sex marriage ban in Pennsylvania being overturned and recent IRS guidance, employers need to be aware of – and immediately implement – significant changes in employee benefit programs and Family and...more

Swiss Bank Pleads Guilty In Alleged Tax Evasion Conspiracy

On May 19, the DOJ announced that a Swiss bank pleaded guilty and entered into agreements with federal and state regulators to resolve a multi-year investigation into the bank’s alleged conspiracy to assist U.S. taxpayers in...more

Clock Is Ticking…Relief for Late Filed GRAs Expected to Expire Soon

Time may be running out for taxpayers to correct technically deficient gain recognition agreements (GRAs) under the relief procedure contained in the Directive on Examination Action With Respect to Certain Gain Recognition...more

Stay Ahead Of The Curve When Choosing Desired Tax Treatment

A foreigner starting business in the U.S. usually hires attorneys for visas, leases and licenses. The tax advisor comes later, when returns loom. This tendency is unfortunate because entering the U.S. starts the clock for...more

Recent Sentences for Federal Tax Crimes in 2014 – Part 3

Today we conclude our review of recent sentences imposed in federal tax crime cases in 2014. In our two previous posts here and here, we reviewed sentences relating to Foreign Bank Account, Tax Evasion, Employment Tax, False...more

Recent Sentences for Federal Tax Crimes in 2014 – Part 2

On Friday, we posted a review here of sentences imposed on defendants in 2014 for Foreign Bank Account, Tax Evasion, and Employment Tax crimes. In this post, we review sentences imposed on defendants in cases involving False...more

Filing From Home, and Health Insurance Reporting on W-2s

According to an IRS release last week, the number of taxpayers electronically filing their own returns from home has increased compared to last year at this time by approximately 6%. Overall, the IRS has received about the...more

Automatic Consolidated Return Elections

Corporations that are directly or through intervening chains of corporations owned 80% or more by a common parent corporation can file a consolidated income tax return. There are many benefits to such returns, including...more

What Green Card Holders Need to Know When Filing Tax Return

The U.S. tax filing deadline is fast approaching on April 15, 2014. Green card holders often have a number of questions when it comes to tax obligations. As we explained in this recent post, green card holders are generally...more

Camp Goes All-In with Comprehensive Tax Plan: Highlights, Tax Reform Status and Impact on Taxpayers

On February 26, Representative Dave Camp (R-Mich.), chairman of the House Ways and Means Committee, released his much-awaited comprehensive tax reform plan (the “Camp Proposal”). That proposal seeks to cut marginal tax rates...more

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