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Recently the District Court for the Western District of Kentucky upheld the imposition of a penalty under I.R.C. sec. 6656(a), which provides a penalty in the case of any failure to deposit a tax payment on the due date unless that failure is due to reasonable cause...
The IRS has created a new form to help small charitable organizations obtain 501(c)(3) tax-status. Instead of filing the 26-page Form 102, qualified organizations may use the IRS' new form, 1023-EZ, to complete the application. An estimated 70 percent of organizations...
The IRS has revised its plan to revoke Individual Tax Identification Numbers (ITINs) after five years of issuance based on the response from taxpayers and their representatives. Instead, beginning in 2016, the IRS will only retire those ITINs which have not been used...
Six years ago, the FTB endeavored to implement a tax system modernization project, Enterprise Data to Revenue(EDR),to update existing systems that would allow the FTB to use data more efficiently and automate manual processes. The project has already doubled its...
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...
