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DOJ Announces Major New Shift in Criminal Sentencing in Offshore Tax Matters
Category: Tax
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…
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The Case Against Do-It-Yourself Tax Returns: You Don't Know What You Don't Know
Category: Tax
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…
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Tax Reporting for Grantor Trusts
Category: Tax
Typically, a trust must file a separate income tax return for each calendar year. However, for most grantor trusts, filing a separate tax return is optional. The general rule and the alternative methods of reporting are described below. When a trust is a “grantor trust” for income tax purposes…
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What Practitioners Need to Know about the New Partnership Audit Rules
Category: Tax
As you’ve surely heard by now, the Bipartisan Budget Agreement of 2015 (“BBA”) enacted new IRS procedures for partnership audits for tax years beginning on or after January 1, 2018. The new audit rules allow the IRS to collect taxes directly from most partnerships rather than from their partners…
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Evading 200 Years of Precedent: The IRS's New Foreign Travel Ban Will Revoke or Deny Passports of Taxpayers Owing More than $50,000 in Tax, Penalties and Interest
Category: Tax
Under the new Section 7345 of the Internal Revenue Code coming into effect in January 2018, Congress has given the IRS the power to “certify” the names of delinquent taxpayers to the State Department for purposes of denying any open application for a passport and barring any foreign travel. Those…
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