Department of Justice’s Swiss Bank Program May Put Some U.S. Taxpayers At Risk
On Aug. 29, 2013, the U.S. Department of Justice (DOJ) and the Swiss Federal Department of Finance signed a joint statement aimed... Read More
IRS Changes Policy, Relaxes Rules for Innocent Spouse Relief
A recent revenue procedure and chief counsel notice reflect significant IRS policy and procedural changes for claims under section 6015(f). The IRS... Read More
A Proposed Voluntary Disclosure Program for the California Franchise Tax Board
This paper provides a framework for discussing the implementation of a voluntary disclosure program for individuals and businesses with the California Franchise... Read More
IRS will not let investors off the hook in overvaluing assets
Individuals should exercise prudence in evaluating transactions designed to generate paper losses on federal income tax returns—so-called tax shelters. Taxpayers should focus... Read More
What Happens When an Individual Fails to Report Foreign Bank Accounts
This article examines what can happen to an individual who fails to report foreign bank accounts on FinCEN Form 114 to the... Read More
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
