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IRS Offers 10 Tax-Time Tips

IRS Offers 10 Tax-Time Tips

IRS Offers 10 Tax-Time Tips The April 18 deadline to file your federal tax return is less than two weeks away. Don’t wait until the last minute. If you haven’t filed yet, the IRS has these 10 tax-time tips to help you. 1. Gather your records.  Make sure you have all your tax records. This includes […]

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Temporary and proposed reliance regs on inherited property consistent basis rules

Temporary and proposed reliance regs on inherited property consistent basis rules

T.D. 9757, 03/02/2016; Reg. § 1.6035-2T; Preamble to Prop Reg 03/02/2016; Prop Reg § 1.1014-10 , Prop Reg § 1.6035-1, Prop Reg § 1.6035-2, Prop Reg § 1.6662-8 , Prop Reg § 301.6721-1, Prop Reg § 301.6721-2 IRS has issued temporary regs that confirm the recently-delayed due date for providing statements to IRS and to […]

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Why we no longer fear the IRS

Why we no longer fear the IRS

Note:  the below newspaper article is the opinion of the author and not my opinion.  The point I believe the author is trying to make is that the IRS needs more staffing to conduct audits-examinations and carry out their overall function; and I wholeheartedly agree to that extent.  However, to the extent the article implies […]

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Unresolved questions of fact surrounded purported alimony agreement including choice of law

Unresolved questions of fact surrounded purported alimony agreement including choice of law

Wolens v. U.S. (Ct Fed Cl 3/4/2016) 117 AFTR 2d ¶ 2016-484 The Court of Federal Claims denied both IRS’s motion to dismiss for failure to state a claim for which relief could be granted, and the taxpayer’s motion for summary judgment, in a refund suit. Although the taxpayer showed sufficient facts to plausibly allege […]

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5 Ways to Sample Americana in Havana

5 Ways to Sample Americana in Havana

As reported in the LA Times, and as originally reported in the NY Times: How to sample Americana in Havana. Every American dashing to Cuba these days seems to share a goal: to see the island “before we ruin it.” But Havana, the city that awaits a historic visit by President Obama and his family next week, owes […]

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Tax Court imposes $20,000 excess litigation costs against attorney for frivolous suit

Tax Court imposes $20,000 excess litigation costs against attorney for frivolous suit

Best, TC Memo 2016-32 In a supplemental opinion, the Tax Court has ordered an attorney to pay nearly $20,000 in excess litigation costs under Code Sec. 6673(a)(2) for unnecessarily bringing and prolonging a collection due process case. The Court found that the attorney acted in bad faith by bringing the case in the first place […]

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Tax Court found taxpayer had no unreported income despite tax evasion conviction

Tax Court found taxpayer had no unreported income despite tax evasion conviction

Senyszyn, (2016) 146 TC No. 9 The Tax Court has concluded that a taxpayer who misappropriated funds from a business associate and failed to report the misappropriated funds as income had no unreported income for the year because he repaid to the associate amounts in excess of those that he took. Accordingly, it found that […]

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President and Treasury update plan for dramatic business & international tax reform

President and Treasury update plan for dramatic business & international tax reform

The President’s Framework for Business Tax Reform: An Update. One day prior to the issuance of major corporate inversion regs, the Administration and Treasury Department released a joint report titled “The President’s Framework for Business Tax Reform: An Update.” In addition to providing the President’s vision for tax reform, the report includes recent figures to […]

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PATH Act improves realty tax breaks but introduces new complications – Part II

PATH Act improves realty tax breaks but introduces new complications – Part II

As a general rule, the cost of commercial real estate improvements is recovered over a painfully long period of 39 years via straight line depreciation only. (Code Sec. 168(b)(3) and Code Sec. 168(c)) However, for specially defined categories of realty improvements, taxpayers may be entitled to the hat-trick of tax breaks: expensing under Code Sec. […]

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IRS discusses application of residual profit-split method to outbound IP transactions

IRS discusses application of residual profit-split method to outbound IP transactions

Residual Profit Split Method – Outbound (ISO/PUO/P_1.7_04(2014)) (Mar. 7, 2016). IRS has released a new international practice unit (IPU) illustrating the application of a specific transfer pricing method, the residual profit-split method (RPSM), to a transaction where a U.S. parent corporation (USP) licenses certain intangible property (IP) to its controlled foreign corporation (CFC) in exchange […]

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36 Hours in Havana

36 Hours in Havana

As reported in the NY Times, 36 Hours in Havana. Havana is no longer frozen in time, at least not completely. With Cuba’s guarded openness to private enterprise grabbing hold, classic American cars and salsa singers now share the cityscape with new and inventive offerings in food, culture, night life and hospitality. No other city […]

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IRS amends transition rules in proposed reliance tax-exempt bond regs

IRS amends transition rules in proposed reliance tax-exempt bond regs

Correction to REG-129067-15, Definition of Political Subdivision. IRS has published a correction to proposed reliance regs, issued last month, that would redefine the term “political subdivision” for tax-exempt bond purposes. The regs’ applicability date was subject to a number of transition rules that IRS has now amended in light of comments received. Background. Under Code […]

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Obama urges Congress to take action on corporate tax reform

Obama urges Congress to take action on corporate tax reform

WASHINGTON (Reuters) – U.S. President Barack Obama on Tuesday urged Congress to take action to stop U.S. companies from taking advantage of tax loopholes that allow them to avoid paying taxes. “When companies exploit loopholes like this… it sticks the rest of us with the tab and it makes hard-working Americans feel like the deck […]

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What’s new for 2016—a roundup of tax changes effective this year — Part III

What’s new for 2016—a roundup of tax changes effective this year — Part III

A large number of important tax changes go into effect this year. Many were ushered in by the Protecting Americans from Tax Hikes (PATH) Act of 2015, although legislation enacted earlier in 2015 and in 2014 also contributed a fair share. Still other changes are the result of various administrative pronouncements by IRS. This article […]

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Innovation boxes and their potential role in international tax reform

Innovation boxes and their potential role in international tax reform

“Encouraging Innovation and the Role of Tax Policy,” Remarks by Jason Furman, Chairman, Council of Economic Advisers. “An Innovation Box Would be a Bad Innovation for American Tax Policy,” Treasury Notes post by Mark Mazur, Assistant Secretary of Tax Policy. So-called “innovation boxes” — essentially, preferential tax regimes for income derived from intellectual property (IP) […]

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Tax shelter promoter penalty isn’t divisible tax for full-payment rule

Tax shelter promoter penalty isn’t divisible tax for full-payment rule

Pfaff v. U.S., (DC 3/10/2016) 117 AFTR 2d ¶ 2016-507 A district court has concluded that the Code Sec. 6707 tax shelter promoter penalty isn’t a divisible tax. Accordingly, where the taxpayer did not pay the full amount of the penalty assessed by IRS, the district court did not have jurisdiction to hear the taxpayer’s […]

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IRS Warns Washington D.C., Maryland, Virginia Residents of New Phishing Scam Targeting National Capital Area

IRS Warns Washington D.C., Maryland, Virginia Residents of New Phishing Scam Targeting National Capital Area

IRS Warns Washington D.C., Maryland, Virginia Residents of New Phishing Scam Targeting National Capital Area IRS YouTube Videos Tax Scams: English | Spanish | ASL Security Summit Identity Theft Tips Overview: English Be Cautious When Using Wi-Fi: English Update Your Password Regularly: English WASHINGTON — As reports of phone scams as well as email phishing […]

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FedEx fails to end New York lawsuit over illegal cigarettes

FedEx fails to end New York lawsuit over illegal cigarettes

NEW YORK (Reuters) – FedEx Corp must face a second lawsuit claiming it shipped thousands of cartons of untaxed cigarettes in New York over roughly a decade, cheating the state and New York City out of tax revenue and undercutting their efforts to curb smoking. In a decision made public on Friday, U.S. District Judge Edgardo […]

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Diplo and Major Lazer Bring Their Brand of Music to Cuba

Diplo and Major Lazer Bring Their Brand of Music to Cuba

As reported in the NY Times, Diplo and Major Lazer bring their brand of music to Cuba. HAVANA — “I know you’ve been waiting a long time for a party like this,” the D.J. and producer Diplo called out to a sea of pulsating young Cubans here on Sunday evening, during a free concert by […]

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Mo Money Tax Return Preparers Plead Guilty to Conspiracy to Defraud the United States and Filing False Tax Returns

Mo Money Tax Return Preparers Plead Guilty to Conspiracy to Defraud the United States and Filing False Tax Returns

According to the Department of Justice Press Release: Two tax return preparers pleaded guilty to one count of conspiracy to defraud the United States and one count of aiding and assisting in the preparation of a false tax return, announced Acting Assistant Attorney General Caroline D. Ciraolo of the Justice Department’s Tax Division and U.S. […]

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Meet Paul Raymond

Meet Paul Raymond

Mr. Raymond is a sought after speaker in tax controversy law by many attorney, accountant, and business groups and at the request of the Internal Revenue Service, has presented programs at the IRS Nationwide Tax Forum, attended by tax professionals throughout the United States.

Additionally, he continues to be an active member in the Section of Taxation, American Bar Association, where he was the Past Chair of the Employment Taxes Committee.

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Member CA Bar Member Orange County Bar US Tax Court Attorney