For one reason or another, I had several calls last year with attorneys and others regarding IRS Streamlined Filing Compliance Procedure submissions gone wrong. In most cases, it was evident that the tax professional had...more
In civil and in criminal cases, the Government must generally act within a certain prescribed time to take action against taxpayers. In legal parlance, this period of time is known as the “statute of limitations.” The...more
2/8/2022
/ Criminal Liability ,
Foreign Bank Accounts ,
Government Investigations ,
Income Taxes ,
Indictments ,
IRS ,
Jury Instructions ,
OVDP ,
Statute of Limitations ,
Tax Evasion ,
Tax Liability ,
Tax Planning
Good tax attorneys will do whatever it ethically takes to win on behalf of their clients. Often, this means the attorney must not only have a good understanding of the substantive provisions at play, but also relevant...more
Also Referred to as Internal Revenue Code Section 6672; I.R.C. § 6672; Section 6672; Trust Fund Recovery Penalty -
Background. In certain instances, the Internal Revenue Code (the “Code”) requires persons to withhold...more
Taxpayers have long utilized trust arrangements for the transfer of wealth to beneficiaries or for the protection of assets from creditors. Generally, there is nothing nefarious about these types of arrangements. Rather,...more
1/14/2022
/ Estate Planning ,
Foreign Trusts ,
Grantor Trusts ,
Income Taxes ,
Internal Revenue Code (IRC) ,
International Tax Issues ,
IRS ,
Tax Amnesty ,
Tax Evasion ,
Tax Planning ,
Tax Returns ,
Voluntary Disclosure
This morning, I woke up to news in the Wall Street Journal that indicated that the United States and the Republic of Malta had entered into a Competent Authority Agreement (“CAA”). Generally, this news would not have caught...more
United States citizens and residents[i] are subject to federal income tax on their worldwide income. For example, even if a United States citizen permanently relocates to a foreign country, he or she will generally continue...more
1/6/2022
/ FBAR ,
FOIA ,
GAO ,
Income Taxes ,
International Tax Issues ,
IRS ,
Offshore Funds ,
OVDP ,
Retirement Plan ,
Revenue Procedures ,
Tax Evasion ,
Tax Planning ,
Voluntary Disclosure
The House Committee of Ways and Means (the “House”) has been busy the last few days. Indeed, the House continues to mark up and work through potential revenue raisers (i.e., tax increases) to help pay for recent legislative...more
10/12/2021
/ Capital Gains Tax ,
Corporate Taxes ,
Foreign Derived Intangible Income (FDII) ,
GILTI tax ,
Income Taxes ,
Internal Revenue Code (IRC) ,
IRS ,
Tax Cuts and Jobs Act ,
Tax Increases ,
Tax Planning ,
Tax Rates
Our firm has written extensively on the topic of cryptocurrency. Indeed, we have even designated an entire resource page on our website to this always interesting and constantly evolving topic...more
Join us as we discuss important developments and bring you up to speed on current initiatives. Many businesses are still facing unprecedented challenges, and we are here to provide insights.
During this information-filled...more
When a taxpayer makes a voluntary payment to the IRS, the taxpayer has the option to designate the application of the payment to certain periods and/or taxes. For example, if a corporation owes federal employment taxes and...more
8/18/2021
/ Employment Tax ,
IRS ,
Payroll Taxes ,
Personal Liability ,
Tax Evasion ,
Tax Liability ,
Tax Penalties ,
Tax Planning ,
Tax Returns ,
Trust Fund Recovery Penalty (TFRP) ,
Trust Funds
In many cases, taxpayers attempt to transfer assets or property to third persons to shield those assets and property from the federal tax lien or federal tax levy. Predictably, the IRS has various tools at their disposal to...more
8/17/2021
/ Criminal Liability ,
FDCPA ,
Fraudulent Transfers ,
Income Taxes ,
IRS ,
Statute of Limitations ,
Tax Evasion ,
Tax Levy ,
Tax Liability ,
Tax Liens ,
Tax Planning ,
Transfer of Assets
Kovel Agreement - The Internal Revenue Service (IRS) has broad statutory authority to investigate and audit taxpayers. In many cases, the IRS attempts to fulfill this statutory authority through seeking communications made...more
Federal tax law permits taxpayers to deduct so-called “theft losses,” provided certain requirements are met. Initially, a taxpayer must show that he or she will not receive compensation through insurance or another third...more
Join us as we discuss important developments and bring you up to speed on current initiatives. Many businesses are still facing unprecedented challenges, and we are here to provide insights.
During this information-filled...more
7/23/2021
/ Automatic Stay ,
Cryptocurrency ,
Enforcement ,
Income Taxes ,
IRS ,
Reasonable Compensation ,
State Taxes ,
Tax Benefits ,
Tax Court ,
Tax Litigation ,
Tax Planning ,
Webinars
A recent Tax Court decision in De Los Santos v. Commissioner illustrates the complexity of split-dollar life insurance arrangements. Taxpayers who participate in these or other types of life insurance arrangements should...more
A recent Tax Court opinion demonstrates the complexities involved when a taxpayer attempts to discharge tax liabilities through bankruptcy proceedings. The case emphasizes the need for an attorney knowledgeable in both tax...more
Federal tax penalties have always been an IRS priority. But, perhaps more so today than three decades ago. For example, in 1987, the IRS reported that it had assessed penalties of approximately $14 billion. Compare that...more
2/4/2021
/ Failure To Pay ,
Failure-to-File ,
Filing Requirements ,
Income Taxes ,
Internal Revenue Code (IRC) ,
International Tax Issues ,
IRS ,
Tax Fraud ,
Tax Liability ,
Tax Penalties ,
Tax Planning ,
Tax Returns