Insights

Blog

Reduction of Tax Attributes under I.R.C. § 108(b)

Steven Walker 4th March 2022
A taxpayer does not always get to eat cake and keep it too. When discharge of indebtedness (other than real property business debt) is excluded from gross income, corresponding reductions must be made to the taxpayer's tax attributes. See Checkpoint
Bankruptcy Tax

Blog

Taxation of the Bankruptcy Estate

Steven Walker 4th March 2022
The taxation of the bankruptcy state is not always obvious, and below are the key highlights for debtors to keep in mind.  The IRS is well versed with these rules, and running afoul can lead to tax controversy issues, such
Bankruptcy Tax

Upcoming Event

COVID-19 Update

Steven Walker 15th May 2020
Due to the COVID-19 pandemic, the firm is currently not scheduling any in-person events or speaking engagements. Please watch for updates regarding webinars, and other virtual engagements to learn more about us and the services we provide.  The firm remains

Blog

IRS and Virtual Currency

Steven Walker 18th August 2019
IRS Has Begun Sending Letters to Virtual Currency Owners Advising Them to Pay Back Taxes, Files Amended Returns; Part of IRS' Larger Efforts The Internal Revenue Service has begun sending letters to taxpayers with virtual currency transactions that potentially failed
Tax Controversy and Litigation

News Featured

IRS Announces New Compliance Campaigns

Steven Walker 14th May 2019
On April 16, 2019 the IRS Large Business and International division (LB&I) announced the approval of three additional compliance campaigns. Two of these campaigns, the Captive Services Provider Campaign and the Loose Filed Forms 5471 Campaign, are of importance to
Tax Controversy and Litigation

Blog

IRS Updated Voluntary Disclosure Practice

Steven Walker 26th March 2019
On November 20, 2018, the IRS issued a Memorandum addressing the process for all voluntary disclosures (both domestic and foreign) following the close of the Offshore Voluntary Disclosure Program on September 28, 2018.  In March 2019, the IRS released new
Tax Controversy and Litigation

Publication

Income Taxation of Trusts in California

Steven Walker July 26, 2018
Recently, in a closely watched case, the California Superior Court in San Francisco rejected the Franchise Tax Board’s long-standing approach to the taxation of trusts.  The court determined that all income, including California-source income, is subject to the apportionment formula
Tax and Estate Planning

Blog

Can the IRS Take My Passport?

Steven Walker 1st October 2017
Are you about to embark on a business trip to Latin America or a well-needed family vacation to Italy or Paris?  Do you work for a technology company and frequently travel overseas to Singapore or other Asian countries for work? 
Tax Controversy and Litigation

Blog

Offshore Tax Compliance

Steven Walker 18th January 2017
Have you received a letter from the Internal Revenue Service (IRS) asking you to come in for an interview? Are you the subject of an IRS examination or target of an IRS criminal case? We are likely to see more
Tax Controversy and Litigation

Blog

Employment Tax Enforcement

Steven Walker 5th May 2016
The Department of Justice has stepped up is prosecutions on the criminal and civil enforcement side against employers who pyramid (business withholds taxes from employees but intentionally fails to remit them to the IRS over several quarters), pay employees in
Tax Controversy and Litigation

Publication

IRS Provides Guidance on FBAR Penalties

Steven Walker November 5, 2015
Tax professionals who advise clients on issues with FinCEN Form 114, Report of Foreign Bank and Financial Accounts (FBAR), should become familiar with IRS Memorandum SBSE-04-0515-0025, “Interim Guidance for Report of Foreign Bank and Financial Accounts (FBAR) Penalties” (5/13/15). The
Tax Controversy and Litigation

Publication

Credit Suisse’s Impact on Its U.S. Clients

Steven Walker August 11, 2014
In the government’s criminal investigation and charging of Credit Suisse AG with helping U.S. taxpayers evade taxes, the IRS used a new and little-known provision of the code, section 6201(a)(4), to ensure that the Swiss bank paid $666.5 million in
Tax Controversy and Litigation

Publication

Can a Taxpayer Refuse an IRS Summons?

Steven Walker April 24, 2014
During the course of an IRS investigation, the IRS has the authority to issue an administrative summons seeking records and testimony (Sec. 7602).  The IRS may summons records, whether they are in the taxpayer’s or a third party’s possession, including
Tax Controversy and Litigation

Publication

A Simplified Procedure to Allow Late Filed Forms 8891 for Individuals With Canadian Retirement Plans and Relief From FBAR Penalties for Foreign Retirement Accounts

Steven Walker January 2, 2013
An individual living in the United States may own a retirement plan from another country. The Internal Revenue Service ("IRS") takes the position that certain foreign retirement accounts are foreign trusts and subject to the onerous reporting requirements of section
Tax Controversy and Litigation