The IRS recently issued Announcement 2014-17, providing an update on jurisdictions treated as having intergovernmental agreements (IGAs) with the United States in order to implement the Foreign Account Tax Compliance Act (FATCA). As of the date of the announcement,...
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The Contractor Ranks Are Growing
The number of workers identifying themselves "independent contractors" is growing in the United States. In 2005 the U.S. Bureau of Labor Statistics determined that the number of independent contractors rose from 6.4% of the workforce in 2001 to 7.4% of the workforce...
Taxpayers can waive the attorney-client privilege by raising good faith and state-of-mind defenses during litigation
The Tax Court recently issued an opinion in AD Investment v. Commissioner, 142 T.C. No. 13, in which the Court granted the IRS's motion to compel the production of documents. The controversy arose in the context of two consolidated Tax Court proceedings involving...
IRS releases 2014 version of “The Truth About Frivolous Tax Arguments”
Last Friday the IRS published an updated version of its publication "The Truth About Frivolous Tax Arguments." This publication provides a list of common frivolous arguments advanced by individuals and groups who oppose compliance with the federal tax laws.Individuals...
California State Board of Equalization Manufacturing Exemption from Sales and Use Tax is Scheduled to Begin in July, 2014
A 2013 law created by Governor Brown's 2013 Economic Development Initiative allows certain businesses in manufacturing or in the fields of biotechnology or physical, engineering, and life sciences to purchase or lease manufacturing or research and development...
Trends in Employment Tax and Employment Law
The Intersection of Employment Tax and Employment LawWe are seeing among our business tax clients a rise in wage and hour litigation, either ancillary to, or independent of, their tax issues. In fact, recently I was giving a presentation to a group of business owners...
IRS Reminds Those with Foreign Assets of U.S. Tax Obligations
The Internal Revenue Service reminds U.S. citizens and resident aliens, including those with dual citizenship who have lived or worked abroad during all or part of 2013, that they may have a U.S. tax liability and a filing requirement in 2014.The filing deadline is...
California “Goes Criminal” with the Revenue Recovery and Collaborative Enforcement Team
On October 7, 2013, Governor Jerry Brown signed Assembly Bill 576 into law, authorizing a pilot program to create the "Revenue Recovery and Collaborative Enforcement Team" (RRCET) consisting of an alliance primarily between the California Department of Justice (DOJ),...
Little Known Facts About Amending Tax Returns with the IRS
What happens when you realize you made an error on your tax return? Most people think they should file an amended tax returns, and in most cases, that would be correct; however, sometimes it is unnecessary. According to the IRS, if you made a math error, the IRS will...
IRS worker classification letter confers jurisdiction on the Tax Court
Yesterday, the Tax Court issued a full Tax Court Opinion, with concurring and dissenting opinions, finding that an IRS letter was sufficient to confer jurisdiction upon the Tax Court. SECC Corporation v. Commissioner, 142 T.C. No. 12. The controversy arose from an IRS...
