In a move that could result in an end to IRS voluntary disclosure participants with offshore accounts, the IRS rescinded approval to participants who were previously granted inclusion in the voluntary disclosure program. Tens of thousands of taxpayers have...
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Tax Controversy
Swiss Bank Wegelin Sentenced to Pay almost $58 Million to the U.S for Conspiracy to Evade Tax
Yesterday, a U.S. court sentenced Swiss Wegelin & Co. to pay almost $58 million (on top of almost $16 million in forfeitures) for helping Americans evade taxes on $1.2 billion in Swiss accounts. In this historic first, the U.S. indicted a foreign bank and obtained...
U.S. Supreme Court Hears Oral Argument on Foreign Tax Credit Dispute
I've recently blogged about the plethora of multi-jurisdictional tax issues which continue to increase as business becomes ever more globalized. On February 20th, the U.S. Supreme Court yesterday heard oral argument in PPL Corp. v. Commissioner. In PPL, the Court is...
Tax Court Denies Conservation Easement Deduction as a Quid Pro Quo Exchange
In Pollard v. Commissioner TC Memo 2013-38, the U.S. Tax Court recently denied a taxpayers' deduction for the donation of a conservation easement where the taxpayer granted the easement pursuant to negotiations with a local zoning authority for approval of a...
California taxpayers and the AMT tax controversy
The fiscal cliff, Washington's latest catch-phrase, holds a surprise for California taxpayers seeking early filing opportunities. According to acting IRS Commissioner Steven Miller, the tax controversy looms trouble on the horizon for nearly two-thirds of America's...
Tax controversy arises with California organization
There are a substantial number of criteria that must be met for an organization to be considered exempt from taxes. Normally, a 501 (c) 3 status allows certain organizations to be free from paying taxes based on their organization's not-for-profit goal. To meet the...
Franchise Tax Board Issues Ruling On Throwback Rule
The California Franchise Tax Board (FTB) recently issued a Chief Counsel Ruling 2012-03 addressing the throwback rules applied to sales made, by California based corporations, to purchasers located in foreign jurisdictions and other states. The throwback rule under...
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...
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...