Yesterday the Supreme Court issued an opinion in which it set forth standards for obtaining an evidentiary hearing in the context of a summons enforcement proceeding. Clarke v. U.S., No. 13-301 (June 19, 2014).The threshold for the government to obtain summons...
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Month: June 2014
Ninth Circuit affirms Tax Court judgment that OPIS tax shelter transaction lacked economic substance
On Friday, the Ninth Circuit Court of Appeals affirmed the Tax Court's decision to disallow a capital loss deduction on the ground that the underlying transaction lacked economic substance and was designed to create substantial capital losses. Reddam v. Commissioner,...
Tax Court rejects $10.7 million in transferee assessments proposed by the IRS
Last week the Tax Court issued an opinion involving proposed transferee liability assessments in excess of $10.7 million in which it rejected the IRS's proposed application of federal law to recast a transaction under the substance over form doctrine. Swords Trust v....
IRS issues first list of approved Foreign Financial Institutions that are in compliance with FATCA regulations.
As promised, the IRS has released the first list of financial institutions that have obtained their Global Intermediary Identification Numbers (GIINs) and have met the other requirements of FATCA. Taxpayers may now search financial institutions by name, country or...
Credit Suisse Pleads Guilty
Swiss authorities have been working with the United States since 2009 to ensure its banks are no longer utilized as a haven for U.S. tax evasion. Swiss government officials and banks have continued to cooperate with the United States in uncovering illegal activities...
87-year old Florida man receives highest FBAR penalty for Swiss account.
A federal jury found that Carl Zwerner must pay more than $2 million for wilfully failing to file Reports of Foreign Bank and Financial Accounts (FBARs). In this case, the IRS sought a 50 percent penalty for each of the four years at issue, for a total of 200 percent...
IRS Contemplates Reduced Penalties for Non-Willful Taxpayers with Unreported Offshore
After serving as IRS Commissioner for only a few months, John Koskinen offers hope for taxpayers with unreported offshore accounts. As the next phase of the Foreign Account Tax Compliance Act (FATCA) begins in July, in which foreign financial institutions will begin...
