A Simplified Procedure to Allow Late Filed Forms 8891 for Individuals With Canadian Retirement Plans and Relief From FBAR Penalties for Foreign Retirement Accounts
An individual living in the United States may own a retirement plan from another country. The Internal Revenue Service (“IRS”) takes the... Read More
Practitioners’ Views of the Tax Court. Pro Bono Legal Services Provided in California to Taxpayers with Docketed Cases Before the United States Tax Court
Mr. Walker was invited to Washington D.C. by the Taxation Section, State Bar of California, to present a position paper regarding practitioners’... Read More
A Rule May Change the Way the IRS Pursues Depositions in United States Tax Court
CPAs often find themselves representing individuals and businesses being audited by the IRS, as well as negotiating settlement of tax disputes... Read More
The Application of Section 482 Transfer Pricing Principles to Financial Transactions, Including Guarantees and Credit Support Arrangements
The issue is the proper tax treatment of a financial guarantee from a parent company to a wholly-owned subsidiary for Federal income... Read More
