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Audit-Examination

IRS directs its auditors regarding treatment of cable operator network assets

IRS directs its auditors regarding treatment of cable operator network assets

IRS’s Large Business & International Division (LB&I) has issued instructions to its auditors on how to apply Rev Proc 2015-12, 2015-2 IRB 265, which provides several safe harbor accounting methods for property costs paid or incurred by cable system operators. LB&I has also provided instructions to auditors on how to handle audits of cable companies […]

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PWC to Pay $65 Million to Resolve Lawsuit Over MF Global but Doesn’t Admit Liability

PWC to Pay $65 Million to Resolve Lawsuit Over MF Global but Doesn’t Admit Liability

NEW YORK (Reuters) – PricewaterhouseCoopers agreed to pay $65 million in cash to settle a lawsuit claiming it fraudulently deceived MF Global Holdings Ltd investors about its auditing of the now-defunct brokerage, which was run by former New Jersey Governor Jon Corzine. The preliminary settlement with investors in MF Global’s common stock, bonds and convertible […]

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Washington Alert – Corporate and individual audits; IRS payment alternatives; Top Ten Identity Theft Prosecutions for Fiscal Year 2014; JCT on Fairness and Tax Policy; Bank Hapoalim; IRS budget

Washington Alert – Corporate and individual audits; IRS payment alternatives; Top Ten Identity Theft Prosecutions for Fiscal Year 2014; JCT on Fairness and Tax Policy; Bank Hapoalim; IRS budget

Corporate examinations are on the same steep downward path as individual audit rates, with business audits down by 6% in fiscal year 2015, IRS Commissioner John Koskinen said in a statement on March 2. This continuing trend is seen across various corporate categories, he said. For example, audit rates are falling for the largest companies […]

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Washington Alert – – Taxpayer Advocate states IRS must conduct self-audit; Audit risk in partnerships; Refunds and changes to procedures for opinion and advisory letters and change of mailing address

Washington Alert – – Taxpayer Advocate states IRS must conduct self-audit; Audit risk in partnerships; Refunds and changes to procedures for opinion and advisory letters and change of mailing address

IRS must conduct a comprehensive self-audit and do so from the perspective of both the agency’s needs and taxpayers’ needs, Nina Olson, the National Taxpayer Advocate, told a House Appropriations subcommittee on Feb. 25. It is essential “that the IRS takes my office’s recommendations seriously” since they stem from cases the Taxpayer Advocate Service works […]

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Tax Court holds longtime artist and art professor not snared by hobby loss rules

Tax Court holds longtime artist and art professor not snared by hobby loss rules

Crile, TC Memo 2014-202 The Tax Court has held that a tenured art professor and career artist had a profit motive with respect to her art under Code Sec. 183 and was engaged in the trade or business of being an artist within the meaning of Code Sec. 162(a) during the years at issue. Click […]

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IRS-approved spinoff of telecom assets highlights expansive approach to REIT form

IRS-approved spinoff of telecom assets highlights expansive approach to REIT form

Real estate investment trusts (REITs) have long been considered tax-favored vehicles for promoting investment in real estate, in that they basically escape entity-level taxation and are required to pay out 90% or more of their income to shareholders. However, there appears to be a growing trend for certain companies that don’t fall cleanly within the […]

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What are your chances of being audited? IRS’s 2013 data book provides some clues

What are your chances of being audited? IRS’s 2013 data book provides some clues

IR 2014-34, 2013 Data Book, see irs.gov/pub/irs-soi/13databk.pdf IRS has issued its annual data book, which provides statistical data on activities conducted by IRS from Oct. 1, 2012, to Sept. 30, 2013, and includes information about returns filed, taxes collected, enforcement, taxpayer assistance and IRS’s budget and workforce. In addition, the data book provides valuable information […]

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IRS revises auditor instructions on production activities deduction in contracting situations

IRS revises auditor instructions on production activities deduction in contracting situations

IRS’s Large Business and International (LB&I) division has, for a second time, revised its previously issued directive to auditors on determining which party qualifies for the Code Sec. 199 domestic production activities deduction where one party contracts out manufacturing to another party. Click here for LB&I-04-1013-008, “Updated Guidance for Examiners on Code Sec. 199 Benefits […]

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Case Alert: Work product rule protected taxpayer’s documents, but attorney-expert rule did not

Case Alert: Work product rule protected taxpayer’s documents, but attorney-expert rule did not

In Veolia Environmental North America Operations, Inc., (DC DE 10/25/2013) 112 AFTR 2d ¶ 2013-5434, a district court has held that certain documents that a U.S. holding company refused to produce in response to an IRS summons were protected by the work product rule. However, it ruled that other of the taxpayer’s documents were not […]

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Generosity, Without a Checkbook – You Don’t Have to Be a Millionaire to Be Charitable

Generosity, Without a Checkbook – You Don’t Have to Be a Millionaire to Be Charitable

Generosity, Without a Checkbook – You Don’t Have to Be a Millionaire to Be Charitable, as reported in the news of the WS Journal. Charitable-giving season is in full force. It’s the time when many charities rely on the generosity of donors to make their budgets for the year and begin to fund their programs […]

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Guidance clarifies beginning of qualified facility’s construction for Code Sec. 45 credit

Guidance clarifies beginning of qualified facility’s construction for Code Sec. 45 credit

In a Notice, Notice 2013-60, 2013-42 IRB, IRS has clarified previous guidance providing two methods (one a safe harbor) that taxpayers may use to establish that construction has begun on a qualified facility eligible for the Code Sec. 45 renewable electricity production tax credit. Under changes made by the American Taxpayer Relief Act of 2012 […]

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Don’t Be a Lousy Gift-Giver – Give treats instead of everyday items and experiences instead of things

Don’t Be a Lousy Gift-Giver – Give treats instead of everyday items and experiences instead of things

Don’t Be a Lousy Gift-Giver – give treats instead of everyday items and experiences instead of things, as reported in the WS Journal. Ma’am, I’m going to have to ask you to put…the socks…down. And, sir, please raise your hands and take two steps back from the ladies’ sweaters. If you are struggling—once again—for some […]

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Proposed Disclosures for Investment Funds Move Toward Release

Proposed Disclosures for Investment Funds Move Toward Release

The FASB wants to shed light on the risks associated with hedge funds and private equity funds that invest in other investment companies. The board plans to release by early 2014 a proposal requiring these investment companies to include information in their financial statement footnotes about their ownership stake, expenses, fees, and their share of […]

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PCAOB Alert Issued to Address Internal Control Failures

PCAOB Alert Issued to Address Internal Control Failures

The PCAOB has issued an audit practice alert to highlight the need for improvements in audits of financial reporting internal controls. The audit regulator issued the alert in light of a 15% failure rate over the past three years in audits of financial reporting internal controls. The PCAOB on October 24, 2013, issued a Staff […]

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Chinese Audit Documents Remain out of Reach

Chinese Audit Documents Remain out of Reach

After years of U.S. effort, it seemed like a breakthrough was achieved when Chinese regulators in July 2013 handed over to the SEC 20 boxes of documents related to a China-based company that was listed on a U.S. stock exchange and suspected of accounting fraud. The SEC has yet to receive paperwork for other companies […]

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Audit Failures Are Blamed on a Lack of Skepticism

Audit Failures Are Blamed on a Lack of Skepticism

PCAOB officials have been alarmed for some time at the high rate of poor audit work they uncover during their accounting firm inspections. Like regulators overseas, PCAOB officials haven’t been able to trace the ultimate causes of the problems, but they’ve found a trait in almost all poorly executed audit work—a failure to exhibit a […]

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Tax Tips: How Long Should I Keep My Tax Records?

Tax Tips:  How Long Should I Keep My Tax Records?

Editor’s Note:  This is a repeat of my blog article which appeared on June 21, 2012.   If I had a dollar for every time that question has been posed to me over the years, . . . The answer is “it depends.”  The article posted in the L.A. Times generated my blog on this subject.  […]

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Tax Tips: How long do I need to keep my records?

Tax Tips:  How long do I need to keep my records?

Editor’s Note: This is a repeat of my blog article which appeared on August 13, 2012.  I’m re-blogging since the question comes up time and time again.  As reported in the OC Register, in the question and answer session with Raphael Tulino, spokesman for the IRS in the Orange County/San Diego area, there is a […]

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PCAOB Release No. 2013-002 Proposes a Reorganization of Audit Standards

PCAOB Release No. 2013-002 Proposes a Reorganization of Audit Standards

The PCAOB issued Release No. 2013-002Proposed Framework for Reorganization of PCAOB Auditing Standards, March 26, 2013, after a unanimous vote in support of the proposal. The proposal is out for comment until May 28. The audit regulator wants to make its standards more readable and easier to understand and is seeking to change the sequentially […]

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Watchdog slams IRS over targeting conservative groups

Watchdog slams IRS over targeting conservative groups

As widely reported in the news, and in Reuters, a U.S. government watchdog faulted the Internal Revenue Service for targeting conservative groups on Tuesday, criticizing senior IRS leaders for poor management of a policy that spun out of control and compromised the tax agency’s political impartiality. As the FBI mounted a criminal investigation of the matter, […]

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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