The Hill: Are you FBAR compliant?
By Kathy Petronchak and Sam Mortazavi April 17, 2014 Published in TheHill.com >>Download the PDF
Undeclared Offshore Assets
We stand at a fascinating point in time with respect to the United States’ continued efforts to find those U.S. taxpayers who have undeclared assets offshore. During my tenure at the IRS, I spent a great deal of time on these efforts. Having led negotiations between the IRS and the Swiss Government in the UBS…
Senate Finance Committee Passes Tax Extenders Bill
On April 3rd, 2014, the Senate Finance Committee passed a tax extenders bill, which included extensions of the R&D credit and the 179D deduction. Both extensions are seamless and extend these provisions through 2015. In addition to extending the R&D credit and 179D deduction, the legislation also significantly expands these tax benefits. Regarding the R&D…
Trust Material Participation Decision Has Significant Implications for Net Investment Income Tax
The U.S. Tax Court issued a decision on March 27th that could significantly impact the extent to which the Net Investment Income Tax (NIIT) applies to trusts. Frank Aragona Trust v. Commissioner of Internal Revenue, 142 T.C. No. 9 (2014). The NIIT generally applies to income earned by a business held in trust unless the…
IRS Outlines New International Offices for Enforcement and Current Priorities
Michael Danilack, Deputy Commissioner of LB&I, spoke about IRS international enforcement efforts on March 18th, 2014 at the 2nd Annual International Tax Enforcement Conference in Washington, D.C. The Deputy Commissioner spoke about recent organizational changes within the Service as well as areas in which the IRS is currently focusing its enforcement efforts. In recent years,…
Law360: FedEx Has Done IUS Developers A Huge Favor
By John Dies and Robert Wonish February 13, 2014 Published in Law360 >>Download the PDF
Tax Court Rules That Refundable Credits Do Not Reduce Tax below 0 for Purposes of 6662 Negligence Penalty
On November 18, 2013, the U.S. Tax Court issued a split decision in Rand and Klugman v. Commissioner, 141 T.C. No. 12 (Docket No. 2633-11, Nov. 18, 2013). The Majority found that for purposes of the I.R.C. § 6662 accuracy related penalty, refundable credits can result in an “underpayment,” but only to the extent that…
The Internal Revenue Service Releases Final and Proposed Net Investment Income Regulations
On November 26th, 2013, the IRS released final and new proposed regulations regarding the Net Investment Income tax. The final regulations covered a wide range of issues, including: withdrawing a proposed method of calculating net gain or loss from the disposition of a pass through entity; allowing a taxpayer to regroup activities on an amended…
