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King v. Burwell The Supreme Court recently heard oral arguments in King v. Burwell. Along with the same sex marriage case, this is the most important case the court will decide this year. Depending on the outcome, the court could change the future course of Obamacare. To quickly review the legal issues, section 36B of…

Appropriate FBAR Penalties

In Moore v. United States, the court in the Western District of Washington held that the IRS needs to comply with the Administrative Procedure Act (APA) when they are making a determination regarding the amount of penalties assessed for failure to file a Report of Foreign Bank and Financial Accounts (FBAR). The court also held…

11th Circuit Affirms Geosyntec Holding

On January 29, the 11th Circuit Court of Appeals affirmed the holding of the United States District Court for the Southern District of Florida in Geosyntec Consultants v. United States of America. Geosyntec Consultants (“Geosyntec”) specializes in “environmental studies and cleanup, infrastructure design and engineering, and natural resources assessment and restoration.” Geosyntec filed suit in…

Congress Attacking Corporate Tax Avoidance

Some members of Congress are receiving praise from the Financial Accountability and Corporate Transparency (FACT) Coalition for introducing the Stop Corporate Inversion Act. This new bill demonstrates an effort to fight against corporate tax avoidance. The new bill is meant to end the treatment of domestic United States corporations, which have been inverted as foreign…

Auditor Independence

Auditor independence is one of the key foundations of the public trust in financial accounting. Some very high profile accounting scandals put this trust in jeopardy. In response, the Sarbanes-Oxley Act of 2002, in conjunction with the Public Company Accounting Oversight Board (PCAOB), have regulated the accounting industry and provided a higher level of scrutiny…

An End to the Double Irish

Companies like Apple, Google, Amazon, and Microsoft have been using what is termed as a Double Irish arrangement to reduce their tax liability. In addition to the low corporate income tax rates in Ireland, this arrangement has been beneficial because of differences in the tax residency laws applicable to corporations in Ireland and the United…

Attorney Presents Zwerner Jury Instructions on Willfulness

On May 28, a Florida jury sided with the United States government in determining that Carl Zwerner, a Florida resident, willfully failed to file reports of foreign bank and financial accounts (“FBAR”) for years 2004 through 2006. The jury assessed $2.2 million in FBAR penalties, plus interest and additions. The penalty amount equaled roughly 145%…


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Washington D.C.
Willard Office Building, Suite 300 1455 Pennsylvania Ave.
Washington, D.C. 20004

© 2021 alliantNational. - All Rights Reserved.

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