A gift basket company and its founder were sued by the IRS just days before Christmas back in 2011. The IRS filed the case saying that the company was not entitled to tax refunds it received for the 2005 and 2006 tax years. In July of this year, a U.S. District Court...
Experience. Dedication. Results.
Tax Controversy
Tyco tax controversy could take years to resolve
According to the IRS, Tyco International Ltd. (Tyco) and some of its former subsidiaries owes the United States government somewhere in the area of $883.3 million in back taxes that have accrued $154 million in penalties. Tyco has let the IRS know that it does not...
OECD Recommends Steps to G8 to End Offshore Tax Evasion
The Organization for Economic Cooperation and Development (OECD) has identified four steps necessary for transparency and the automatic exchange of information regarding financial accounts through a cost effective and secure system, in an effort to end offshore tax...
Disproportionate Penalties for FBAR Non-Filers
In the National Taxpayer Advocate's 2012 Report to Congress, it issued data highlighting the disproportionate penalties to account holders with undisclosed offshore accounts who participate in the IRS' Offshore Voluntary Disclosure Program (OVDP). Generally, if a...
Affordable Care Act or “Obamacare” Tax Considerations
The Affordable Care Act ("the Act," commonly referred to as "Obamacare") contains currently implemented tax provisions, as well as other that will be implemented during the next several years. According to the Internal Revenue Service, the following are some examples...
Mexican Land Trust arrangements deemed not to be Trusts under Treasury Regulation section 301.7701-4(a)
Revenue Ruling 2013-14 describes a typical Mexican Land Trust (MLT), or fideicomiso, and concludes that the arrangement is not a trust within the meaning of § 301.7704-4(a).
IRS claims it can read your e-mail without a warrant
Recently, the IRS has publicly stated their position that there is no expectation of privacy regarding electronic communications, and that they may be able to view your electronic communications without a warrant.To read more, click here.
Tax Court Limits Northern California Couples’ Real Estate Rental Loss Due To Passive Activity Rule
With the economic downturn the U.S. tax court has seen its fair share of cases tackling the limitation of real estate losses.In Hassanipour v. Commissioner, the U.S. Tax Court, held that a couple's losses from their rental activities were limited under IRC section...
Tax Court Determines Value of Interests in Artwork for Estate Tax Purposes
In Estate of Elkins v. Commissioner, the Tax Court rejected the IRS's argument that no discount should be allowed in valuing fractional interests in artwork in a decedent's estate. The Court, however, allowed only a ten percent discount to account for uncertainties a...
U.S. Tax Court Finds Construction Workers Classified as Employees; General Contractor Liable for Employment Taxes
In Kurek v. Commissioner, T.C. Memo 2013-64, the U.S. Tax Court held that a general contractor should have treated construction workers on his projects as employees rather than independent contractors. During the tax year at issue, Mieczyslaw Kurek hired approximately...