An article in the Sunday edition of the Washington Post details the continued erosion of Switzerland's banking secrecy laws. As many of Europe's economies continue to experience stagnant economic conditions, many countries have taken aim at Switzerland's vaults in the...
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IRS Provides Guidance to Foreign Financial Institutions on FATCA Timelines
The US Treasury Department (Treasury Department) and the Internal Revenue Service (IRS) issued Announcement 2012-42 providing guidance on various timelines for withholding agents and foreign financial institutions (FFIs) to complete due diligence required under the...
New York Court Holds That Lap Dances are Not Art and are Taxable
The New York Court of Appeals has affirmed a previous judgment by the state's Appellate Division that lap dances are not art, and thus are not exempt from state sales taxes.In New Loudon Corporation v. State of New York Tax Appeals Tribunal, the plaintiff, Nite...
First Time Penalty Abatement Relief Often Overlooked
The Treasury Inspector General for Tax Administration (TIGTA) recently audited the IRS to determine whether penalty abatement for the failure to file a tax return, or failure to pay a tax liability was consistently and accurately applied to taxpayers who qualified....
Chinese Renounce U.S. Citizenship Citing the Sophisticated Systems the U.S Utilizes to Fight Tax Evasion
The South China Morning Post is reporting that many former Chinese Nationals are thinking about renouncing their US citizenship. Such actions would have been almost unimaginable a decade ago, when getting a US passport was the ultimate Chinese status symbol.The reason...
Tax Court Lacks Jurisdiction to Review IRS’s Refusal to Pursue Whistleblower’s Claim
In a case of first impression, the United States Tax Court held that it lacked jurisdiction under Internal Revenue Code (IRC) Section 7623(b) to review the IRS's refusal to pursue a whistleblower's claim. Cohen v. Commissioner, 139 T.C. No. 12 (Oct. 9, 2012)In this...
Federal Judge Shoots Down Hundreds of Millions in Tax Losses claimed by Broadcom Co-Founder
In Broadwood Investment Fund LLC v. United States, No. 08-0295 (C.D. CA Sept. 21, 2012), a California federal district court judge rejected, on summary judgment, a bid by Broadcom co-founder Henry Nicholas, III, to claim hundreds of millions in tax losses from a tax...
Ninth Court to Rule on 5th Amendment Privilege of Tax Records.
The Recorder, a California legal publication, reports on oral argument in a Ninth Circuit case involving the act of production doctrine. Under this doctrine, a person can invoke his Fifth Amendment rights against the production of documents only where the very act of...
Mailbox Rule Does Not Apply To All Fed Ex Deliveries
Not rain, nor sleet, nor snow will stop the U.S. Postal Service from delivering your Tax Court Petition, but try to save a few bucks by using Federal Express' "Express Saver Third Business Day" and your petition is not considered "mailed" according to the U.S. Tax...
FATCA News – United Kingdom is First to Sign with the Treasury Department
This week the Treasury Department and the United Kingdom signed a bilateral agreement to implement the information reporting and withholding tax provisions under the Foreign Account Tax Compliance Act (FATCA). The model agreement was developed in July 2011 with input...
