It is no secret that the world is increasingly becoming a smaller place, especially when measured by the Internal Revenue Service's (IRS) long reach. An article in the New York Times discusses how Americans living abroad are coming under pressure to declare foreign...
Experience. Dedication. Results.
Photo of Professionals at Law Office of Williams & Associates, P.C.
IRS
Attorney Convicted of Tax Fraud and Obstruction of Justice Crimes
The U.S. Department of Justice (DOJ) and the Internal Revenue Service (IRS) recently announced that attorney Aristotle "Rick" Matsa was convicted of tax fraud and obstruction of justice related offenses, including witness tampering. Additionally, Mr. Matsa and his...
Taxpayer Not Required to Recognize Discharge of Indebtedness Gain on Installment Notes Until Disposition
required to recognize income from discharge of indebtedness, gain deferred pursuant to its installment sale, or gain on a disposition of an installment obligation.The taxpayer sold property to a new corporation controlled by a private equity firm in exchange for cash...
IRS Delays the Effective Dates for Reporting by Brokers for Debt Instruments, Options Transactions
In Notice 2012-34, the IRS has announced it will delay the proposed effective dates for information reporting by securities brokers for transactions related to debt instruments and options by one year.The new regulations recommend changes to the reporting requirements...
Tax Court gives Taxpayers a Big Victory
The Wall Street Journal just reported that "the Tax Court just blessed a technique that owners of closely held businesses-and wealthy families-can use to pass assets to heirs with a minimum of taxes and complications." The ruling in Wandry v. Commissioner is causing...
Supreme Court rules against the IRS
In United States v. Home Concrete & Supply, LLC, the US Supreme Court affirmed the decision of the Fourth Circuit, holding that Section 6501(e)(1)(A) of the Internal Revenue Code, which extends the limitations period for the government to assess a deficiency...
IRS Advises that Sales at Prices Below Acquisition Cost Satisfy All-Events Test.
In field attorney advice memo 20121602F, the IRS determined that the "all-events test", which determines when a liability is incurred and deductible, is met when a wholesaler sells products to a pharmaceutical company at prices below the wholesaler's acquisition...
Hollow Victory for Taxpayer as IRS Acquiesces in Estate Tax Refund Suit but Declines to Actually Issue Refund.
In an Action On Decision (AOD), the IRS announced that it will acquiesce, in the result only of a decision in which the U.S. District Court held that a decedent's estate was entitled to a refund of deficiency assessed on contingent bequests. An AOD is a formal...
IRS Chief Counsel Issues Guidance on the Economic Substance Doctrine
IRS Notice CC-2012-008 announces new Chief Counsel Coordination Procedures for asserting the economic substance doctrine, which was recently codified in Internal Revenue Code Section 7701(o). The notice is intended to ensure that the economic substance doctrine is...
IRS Commissioner Will Leave in November, Recounts Offshore Initiatives
Internal Revenue Service (IRS) commissioner, Douglas Shulman, said he doesn't intend to stay in the job after his five-year term expires in November. "My plan is to leave at the end of my term," he said during a question-and-answer session today at the National Press...
