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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...
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,...
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....
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...
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...
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...
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...
According to the Internal Revenue Service (IRS), it will hold two free webinars for small businesses on this year's "Small Business Week," May 12 to 16. The Webinars focus on several key tax benefits and a special relief program for employers who reclassify their...
In a Summary Opinion, the Tax Court found that a taxpayer did not have $10,000 in unreported income with regard to settlement proceeds resulting from a mortgage fraud lawsuit. Kadir v. Commissioner, T.C. Summ. Op. 2014-43.In Kadir, the taxpayer had refinanced his...
The IRS provides further clarification and announces its intention to further amend certain Regulations concerning FATCA. In order to facilitate an orderly transition for withholding agents and Foreign Financial Institutions, the years 2014 and 2015 will be treated as...
