I Missed a Tax Election…Now What? Requesting 9100 Relief
What do we, as tax professionals, do when we discover (or our clients discover) that a tax election has been inadvertently missed? There may be a solution for some missed elections. Regulations §§ 301.9100-1 through 301.9100-3 contain rules permitting extensions of time for certain late tax…
Is the Supreme Court Set to Extinguish Bellas Hess' Bright Line Rule Barring Imposition of Sales Tax on Out-of-State Internet Sellers Later This Year?
February 8, 2018
by Anton L. Janik, Jr.
Twenty-six years ago in Quill Corp. v. North Dakota the U.S. Supreme Court held that the Bellas Hess bright line rule that out-of-state sellers cannot be held liable for collecting and remitting sales tax to any state unless the seller had physical presence in that state, was a precedent that still…
The New Deduction for Pass-Through Income (or How Congress Failed at Tax Simplification)
One of the more significant changes in the recently enacted Tax Cuts and Jobs Act is new Internal Revenue Code Section 199A, Qualified Business Income. Although touted as providing tax simplification, the Tax Cuts and Jobs Act created a pretty complex new tax concept – the pass-through deduction. …
DOJ Announces Major New Shift in Criminal Sentencing in Offshore Tax Matters
December 8, 2017
by Anton L. Janik, Jr.
At the 34th Annual National Institute on Criminal Tax Fraud in Las Vegas yesterday afternoon, Mark Daly, DOJ Tax Division Senior Litigation Counsel announced a major new shift in how the Department of Justice plans to argue offshore tax prosecution defendants should be sentenced. Instead of…
The Case Against Do-It-Yourself Tax Returns: You Don't Know What You Don't Know
November 6, 2017
by Ashley L. Gill
In an effort to comply with the increasing complexity of the Internal Revenue Code (the “Code”) and the regulations promulgated thereunder, many taxpayers are looking to tax preparation software for assistance in preparing their own tax returns. According to the IRS’s filing season statistics for…