I was recently interviewed by the Wall Street Journal about the IRS LB&I audit campaigns discussed here. An interesting part of the conversation included a discussion of why the
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Civil Tax
Sixth Circuit Acknowledges Some Tax Laws Sanction Tax Avoidance
By Fox Rothschild LLP on
In a strongly worded opinion that is very favorable for taxpayers who engage in sophisticated tax planning, the Sixth Circuit overturned a Tax Court opinion denying the benefits of a…
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California District Court Finds Failure to File FBARs was Willful Despite Application for Voluntary Disclosure Program
By Fox Rothschild LLP on
The Bank Secrecy Act requires U.S. taxpayers to file FBARs with the U.S. Treasury disclosing any interest in, or signature authority over, foreign financial accounts with assets in excess of…
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IRS Announces 13 Issues Targeted Under its New Audit Campaigns
By Fox Rothschild LLP on
On January 31, 2017, the IRS announced the initial rollout of its new audit strategy and identified 13 specific issues (campaigns) it will be targeting. The IRS is moving toward…
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Israel, the Republic of Korea and Saint Lucia Will Now Provide IRS Information on Bank Interest paid to Nonresident Aliens
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The IRS released an advanced version of Revenue Procedure 2016-56 that requires three more countries – Israel, the Republic of Korea and Saint Lucia – to participate in the automatic…
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Court Authorizes IRS to Seek Identities of Bitcoin Users and Users of Other Virtual Currencies
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On November 30th, a federal district court in California entered an order authorizing the IRS to serve a John Doe Summons on Coinbase Inc. seeking information about U.S.
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IRS Unveils Fast Track Mediation Collection Program, Offering Expedited Resolution for Certain Collection Cases
By Fox Rothschild LLP on
Effective November 18, 2016, Revenue Procedure 2016-57 established the Small Business/Self-Employed (“SB/SE”) Fast Track Mediation Collection (“FTMC”) program to allow taxpayers and the IRS to resolve disputes quickly with an…
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IRS Announces Major Changes to Appeals Procedures
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In October 2016, the IRS declared that in-person conferences will no longer be the default method for Appeals conferences. The IRS also made several key Collection and Examination policy clarifications…
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IRS Imposes New Reporting Requirements on Certain Micro-Captives
By Fox Rothschild LLP on
In 2015, the IRS first included micro-captives, or small insurance companies which have elected under section 831(b) to exclude premiums from their income, on its annual dirty dozen list. At…
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Managing the Money From Legalized Marijuana: Accounting Tips for the Cannabis Industry
By Fox Rothschild LLP on
Tax and accounting issues you should not ignore when setting up your cannabis business:
The Trouble With Cash-Based Businesses
- Internal Controls – any cash-based business is closely scrutinized by the