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In a move that could result in an end to IRS voluntary disclosure participants with offshore accounts, the IRS rescinded approval to participants who were previously granted inclusion in the voluntary disclosure program.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...
In February, the Franchise Tax Board (FTB) lost a case, DANIEL V INC. v. Franchise Tax Board, in a Los Angeles Superior Court where it had asserted that a Nevada Company was commercially domiciled in California because it was owned by a California resident, Ron Lane....
The co-owner and CEO of a California investment firm recently pleaded guilty to federal charges of tax fraud and wire fraud. According to reports, the 66-year-old Diamond Bar man operated a day-trading scheme that took in $49 million from investors from 2005-2011. He...
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...
The Financial Crimes Enforcement Network (FinCEN) has proposed changes to the FBAR to standardize it with other BSA electronically filed reports, add the capability for a third party preparer to file the report and record taxpayer identification numbers. To review the...
The IRS has announced both permanent and temporary modifications of eligibility requirements to its Voluntary Worker Classification Settlement (VWCS). Previously, employers who were under IRS audit could not participate. Now, however, employers under IRS audit (other...
The California FTB shared some of the most common tax audit issues for corporations today. Heading the list is the cost of performance and sourcing of intangible sales, along with sales factor and gross receipts, abusive tax shelters and credits. If you have questions...
California entrepreneurs were likely very surprised recently when they found out they were liable for paying four years' worth of taxes to the state that they were previously not required to pay. Last December, the Franchise Tax Board eliminated a capital gains tax...
There is currently a plethora of cases involving horse breeding or other horse related activities flooding the U.S. Tax Court. One such recent case, involved former San Francisco 49er linebacker Bill Romanowski. In the typical hobby loss case, the taxpayer puts a lot...
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...
