The Federal Tax Lien and Exemptions: Handling IRS Enforcement of Valid Tax Liens
This article provides advice for guiding clients that seek to discharge taxes in bankruptcy and practical guidance to help avoid common pitfalls... Read More
Consequences of Failing to Report Federal Changes to the California FTB or Filing State Returns
On Oct. 14, 2021, the Ninth Circuit Court of Appeals in Berkovich affirmed the decision from the Bankruptcy Appellate Panel (BAP) that because a... Read More
Handling Audits of Delinquent International Information Returns
This article examines strategies for handling an IRS investigation of international returns, and recommends ways to improve audits, foster taxpayer compliance, and... Read More
Comments and Proposed Guidance on the IRS’ Revocation or Denial of Passports
This paper was presented to the IRS in Washington, D.C. at the California Lawyers Association, Taxation Section, 2019 Washington D.C. Delegation. The... Read More
Is Your Client the Subject of an FBAR Examination?
Has a client received a letter from the IRS asking to schedule an appointment to examine the client’s compliance with the requirement... Read More
Income Taxation of Trusts in California
Recently, in a closely watched case, the California Superior Court in San Francisco rejected the Franchise Tax Board’s long-standing approach to the... Read More
IRS Closer to Obtaining Virtual Currency Records
On Nov. 30, 2017, after a lengthy summons enforcement proceeding, a federal district court issued an order granting in part and denying... Read More
IRS New Compliance Campaigns and International Audits of Individuals
On November 3, 2017, the IRS announced the roll out of 11 Large Business and International (LB&I) Compliance Campaigns.LB&I previously announced the... Read More
Form W-9 or W8-BEN? How to Classify a Dual Resident Taxpayer
Mr. Walker was invited to Washington D.C. by the Taxation Section, State Bar of California, to present a position paper regarding how... Read More
Is My Case Criminal? Civil Fraud vs. Tax Evasion
This article examines the concept of willfulness in the context of international tax enforcement, focusing on the factors that can transform a... Read More
