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IRS admits rules are needed on penalty for intentional failure to file electronically

IRS admits rules are needed on penalty for intentional failure to file electronically

Chief Counsel Advice 201603031 IRS has issued a Chief Counsel Advice (CCA) which notes that it hasn’t issued rules for calculating the penalty for intentionally failing to file information returns electronically. The CCA suggests internal IRS procedures for arriving at future IRS policy in this matter and sets out suggestions of how that calculation might […]

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Tax Court doesn’t let IRS proceed with collection of taxpayer’s unpaid taxes by levy

Tax Court doesn’t let IRS proceed with collection of taxpayer’s unpaid taxes by levy

Allen, TC Memo 2016-13 In reviewing a determination by the IRS Appeals Office to proceed with collection of the taxpayers’ unpaid Federal income tax by levy, the Tax Court concluded that there were genuine questions of material fact to be decided at trial with regard to the taxpayers’ receipt of a notice of deficiency and […]

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Internal IRS guidance explains international information exchange programs

Internal IRS guidance explains international information exchange programs

IRS has released three new International Practice Units (IPUs) providing guidance to its examiners on exchange of information (EOI) programs. “EOI” refers to the sharing of tax-related information between two or more countries for tax administration and enforcement purposes, generally under the provisions of U.S. income tax treaties and other international tax information sharing agreements. […]

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Julius Baer settling U.S. tax case, ex-bankers to plead guilty

Julius Baer settling U.S. tax case, ex-bankers to plead guilty

NEW YORK (Reuters) – Two former Julius Baer bankers are expected to plead guilty on Thursday for helping wealthy American clients evade taxes as U.S. prosecutors unveil a $547 million settlement with the Swiss bank, a person familiar with the matter said. Daniela Casadei and Fabio Frazzetto, former client advisers at Julius Baer, are expected […]

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31 countries sign international agreement on country-by-country reporting, but not U.S.

31 countries sign international agreement on country-by-country reporting, but not U.S.

OECD press release (Jan. 27, 2015). On January 27, finance ministers and top officials from 31 countries — which didn’t include the U.S. — signed the Multilateral Competent Authority Agreement on the Exchange of Country-by-Country Reports (the Agreement), according to an OECD press release. This is the first signing ceremony for the Agreement to facilitate […]

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Notice sets out method for RIC’s refund of foreign tax that was treated as paid by shareholders

Notice sets out method for RIC’s refund of foreign tax that was treated as paid by shareholders

Notice 2016-10, 2016-6 IRB In a Notice, IRS has provided guidance with regard to regs it intends to issue on alternative methods that regulated investment companies (RICs) and their shareholders may use to satisfy their obligations under Code Sec. 853 and Code Sec. 905(c) where a RIC receives a refund of a foreign tax that […]

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Tax Court – ESOP violating anti-alienation and plan document requirements was disqualified

Tax Court – ESOP violating anti-alienation and plan document requirements was disqualified

Family Chiropractic Sports Injury & Rehab Clinic, Inc., TC Memo 2016-10 The Tax Court has concluded that there was no abuse of discretion in IRS’s determination that an employee stock ownership plan (ESOP) was not qualified under Code Sec. 401(a) for its 2010 and subsequent plan years and that the related trust wasn’t exempt under […]

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New form sets out rules for reporting basis of decedent-owned property

New form sets out rules for reporting basis of decedent-owned property

Form 8971, Information Regarding Beneficiaries Acquiring Property From a Decedent (January 2016). IRS has released the final version of new Form 8971, which, pursuant to legislation enacted in 2015, must be used to report the final estate tax value of property distributed or to be distributed from an estate, if the estate filed a Federal […]

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‘Sharing economy’ can complicate U.S. tax filings

‘Sharing economy’ can complicate U.S. tax filings

NEW YORK (Reuters) – Uncle Sam is waiting for his cut from American taxpayers, including those who participate in the so-called sharing economy – doing side gigs like renting out their apartments, driving for Uber or running random errands for strangers on TaskRabbit.com. According to a recent data, Intuit Inc, the owner of the TurboTax […]

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IRS draws conclusions regarding taxpayer’s income from nonqualified stock option

IRS draws conclusions regarding taxpayer’s income from nonqualified stock option

Chief Counsel Advice 201603025 In Chief Counsel Advice (CCA), IRS drew various conclusions regarding a taxpayer recognizing income form a nonqualified stock option that he received, including whether the underlying stock was readily tradable on an established securities market. Background. Under Code Sec. 409A(a)(1)(A), all amounts deferred under a nonqualified deferred compensation (NQDC) plan for all […]

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Has success overpriced O.C.? Big Orange Index shows 6 years of growth, but some indicators are down, hinting at trouble ahead

Has success overpriced O.C.? Big Orange Index shows 6 years of growth, but some indicators are down, hinting at trouble ahead

As reported in the OC Register, Success does come with a price tag. Orange County’s economy begins 2016 on a six-year winning streak. But the extended upswing is creating challenges that may limit the local business climate’s advance. My Big Orange Index, a compilation of three dozen benchmarks of local economic performance, hit a new record […]

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Changes to Compliance Fees for Voluntary Correction Program (VCP)

Changes to Compliance Fees for Voluntary Correction Program (VCP)

In postings to its website, IRS has noted that the current IRS forms for submitting certain employer plan user fees, including fees for employee plan determination letters, show fees that are no longer up to date, and has instructed taxpayers as to how to submit those fees. Background. The Employee Plans Compliance Resolution System (EPCRS) provides […]

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Wal-Mart blasts Puerto Rico tax ahead of trial

Wal-Mart blasts Puerto Rico tax ahead of trial

SAN JUAN (Reuters) – Wal-Mart’s Puerto Rico subsidiary on Monday said a U.S. commonwealth tax on big companies is discriminatory, setting the stage for a trial starting on Tuesday that could threaten a tax increase Puerto Rico hoped would protect local businesses and jump-start its economy. In court papers filed ahead of the trial, in […]

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Tax Court – German taxpayer was subject to regular U.S. income tax and covered expatriate tax

Tax Court – German taxpayer was subject to regular U.S. income tax and covered expatriate tax

Topsnik, 146 TC No. 1 The Tax Court has held that a taxpayer with connections to Germany, including a German passport, who had a U.S. green card for many years, was not a German resident, and was therefore subject to U.S. taxation as a nonresident. It also found that he was subject to the Code […]

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A bad appraisal: How buyer and seller can compromise

A bad appraisal: How buyer and seller can compromise

As reported in the OC Register, Commercial real estate appraisals are required if you are financing a purchase through a lender – conventional or otherwise. The possible exception might be an owner-financed purchase. In that case, the owner becomes the bank and may not require an appraisal. An appraisal is a lender’s way of “hedging their […]

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Washington Alert – DOJ continues foreign tax evaders; IRS webinar on changes in retirement plans; Advance Pricing and Mutual Agreement office (APMA) will begin accepting requests for bilateral advance pricing agreements (APAs) between the U.S. and India

Washington Alert – DOJ continues foreign tax evaders; IRS webinar on changes in retirement plans; Advance Pricing and Mutual Agreement office (APMA) will begin accepting requests for bilateral advance pricing agreements (APAs) between the U.S. and India

There will be no letup in the federal government’s ongoing campaign targeting U.S. taxpayers who hide foreign accounts and attempt to evade U.S. tax obligations, a key Justice Department (DOJ) official said on Jan. 29. In 2016, tax professionals will see “additional civil enforcement actions and ongoing and new criminal investigations and prosecutions,” Caroline Ciraolo, […]

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EU antitrust chief rejects U.S. criticism of Apple, Starbucks tax cases

EU antitrust chief rejects U.S. criticism of Apple, Starbucks tax cases

BRUSSELS (Reuters) – Europe’s antitrust chief signalled on Monday her determination to go after Apple, Starbucks and McDonald’s over their tax deals in the bloc, dismissing U.S. criticism of her crackdown on the companies. European Competition Commissioner Margrethe Vestager’s comments come three days after senior U.S. Treasury official Robert Stack met her team in the […]

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Supplemental notice of determination didn’t confer Tax Court jurisdiction

Supplemental notice of determination didn’t confer Tax Court jurisdiction

LG Kendrick, LLC, (2016) 146 TC No. 2 The Tax Court has held that it didn’t have jurisdiction to review the filing of a notice of Federal tax lien (NFTL) for a taxpayer for a certain period, concluding that, where the original notice of determination was insufficient to confer jurisdiction on the Court, a supplemental […]

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Puerto Rico study optimistic on job creation under tax breaks

Puerto Rico study optimistic on job creation under tax breaks

SAN JUAN (Reuters) – Tax incentives aimed at spurring Puerto Rico’s economy have created 5,800 jobs in the four years since their enactment, but could create 50,000 more jobs in the next eight, a study commissioned by the island’s government said. The study, released on Tuesday by the economic consulting firm Estudios Tecnicos, said the […]

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Washington Alert – Swiss Bank Program & HSZH Verwaltungs AG , GAO faults SB/SE audits, IRS issues refunds fast

Washington Alert – Swiss Bank Program & HSZH Verwaltungs AG , GAO faults SB/SE audits, IRS issues refunds fast

The Justice Department (DOJ) announced on Jan. 27 that it had reached its final non-prosecution agreement under the so-called Category 2 component of the Swiss Bank Program. HSZH Verwaltungs AG reached a resolution that requires the bank to pay a penalty of $49.8 million. Since last March, when the first non-prosecution agreement was made public, […]

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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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