Business Better Podcast Episode: Tax Audits, Investigations, and Global Enforcement - A Conversation with IRS Special Agent Jonathan Schnatz
Domestic Tax Planning - Podcast with Janathan Allen
Let's Talk About Taxes and Divorce
Nonprofit Basics: Operating Foundation Rules
Podcast: Got Mail? What to Do When the IRS Contacts You [More with McGlinchey, Ep. 42]
Let's Talk What to Bring to Your First Family Law Appointment
The Renoir Spelling Bee
The Presumption of Innocence Podcast: Episode 2 - Avoid Falling Prey: The Dirty Dozen and Other Trending Tax Scams
PODCAST: Williams Mullen's Benefits Companion - Plan Administrators’ 2020 Year-End Checklist
The Freeman Law Project – Episode 22 – Trump v. Vance - The Second Circuit Weigh In
The Freeman Law Project – Episode 21 – The New York Times and President Trump's Taxes
On-Demand Webinar | PPP Loan Forgiveness: Employment and Tax Issues for Borrowers
Williams Mullen's Comeback Plan: Part I – State & Local Tax (SALT) Compliance During COVID-19: What to Do When You’re Behind
Jones Day Presents: LB&I Examination Strategies: Process Overview
Jones Day Presents: Strategies for Dealing with the IRS: Going to Court
This Week in FCPA-Episode 56
US tax filing is underway, and as we approach the April 15 deadline we would like to offer additional tax updates and information for US expatriates. The first and most important thing for US expatriates to know about taxes...more
In IRS Notice 2023-71 (the “Notice”), the Internal Revenue Service (“IRS”) granted a postponement until October 7, 2024 for various time-sensitive filing and payment deadlines for taxpayers affected by the terrorist attacks...more
Harrington v. Commissioner - In Harrington v. Commissioner of Internal Revenue, George S. Harrington (Harrington) challenged tax deficiencies and fraud penalties assessed for tax years 2005 through 2010. Originally...more
Summary: At its core, this 31-page opinion regards married U.S. citizen taxpayers, Leigh Fairbank (Leigh) and Barbara Fairbank (Barbara), challenge to deficiency notices issued for the tax years in issue (2003 through 2009...more
The New Jersey Tax Court recently granted a pro se taxpayer’s motion for summary judgment and ruled that the Division of Taxation was barred by the statute of limitations from recovering an erroneous income tax refund payment...more
The Michigan Court of Appeals held that the statute of limitations does not prevent the Department of Treasury (“Treasury”) from reducing a credit in an otherwise closed year, despite acknowledging flaws in how the audit was...more
When is a protective refund claim available? Taxpayers often face uncertain outcomes in litigation or business transactions, giving rise to contingent tax refund claims. For example, if a pending lawsuit ends in a favorable...more
Regulations frequently change as Congress adopts new policies and the IRS issues new or revised regulations implementing those policy changes. Tax elections based on existing law cannot be revoked if later regulatory changes...more
The Internal Revenue Service (IRS) must follow the “statute of limitations” as stated in Internal Revenue Code (IRC) Section 6501 to “assess” additional federal tax. Likewise, taxpayers must seek a tax overpayment or refund...more
In The Merry Wives of Windsor, William Shakespeare penned the famous line: “Better three hours too soon than a minute too late.” And such sentiments of time are certainly true in the tax world. One minute late may have...more
Freeman Law’s “The Tax Court in Brief” covers every substantive Tax Court opinion, providing a weekly brief of its decisions in clear, concise prose. The Week of June 14 – June 18, 2021 - Bell Capital Management, Inc....more
In Notice 2004-45, 2004-2 C.B. 33, the IRS put taxpayers who were asserting to be bona fide residents of the U.S. Virgin Islands (USVI) and who were not following the requirements of meeting the applicable bona fide residency...more
International information return penalties are civil penalties assessed by the IRS against a United States person for failing to timely file complete and accurate international information returns required by specific...more
Initiative Temporarily Suspends Many Payment Requirements and Enforcement Actions - Earlier this week, the Internal Revenue Service (“the Service”) unveiled its new People First Initiative (“the Initiative”), an effort by...more
Wednesday, March 25th, in the wake of the recent decision by the Internal Revenue Service (“IRS”) to extend the income tax filing and payment deadlines to July 15, 2020, it announced a new taxpayer-friendly program called the...more
March 25, 2020 – The IRS announced a major suspension of many “tax compliance” dates and tax collection measures. Published in IRS Information Release 2020-59 as the “People First Initiative”, the IRS announced that it is...more
In October 2005, Carlton Stauffer executed a durable power of attorney (“DPA”) naming his son, Hoff Stauffer, as his agent. Stauffer v. Comm’r, No. 18-2105 (1st Cir. Sept. 16, 2019). The DPA granted broad authority to Hoff...more
TRIBUNAL REMANDS $100 MILLION SALES TAX REFUND CASE TO ALJ - After the New York State Appellate Division reversed the Tax Appeals Tribunal’s earlier decision denying a sales tax refund of over $100 million, the Tax...more
A New York City Administrative Law Judge held that a taxpayer’s real property transfer tax returns were not false or fraudulent and therefore the Department of Finance could not reopen the closed three-year statute of...more
In Mission Funding Alpha, the Pennsylvania Supreme Court recently held that the statute of limitations for a corporation to file a refund claim in Pennsylvania begins to run when the corporate tax return is due, not when the...more
This week, Jay and I have a wide-ranging discussion on some of the week’s top compliance related stories. We discuss: 1. The Kokesh case at the US Supreme Court is significant for SEC enforcement of the FCPA around profit...more
On February 28, 2017, the Michigan Department of Treasury (the Department) issued a Notice to Taxpayers (the Notice) explaining its approach in administering the now final Michigan Court of Appeals decision in LaBelle...more
The Service generally has three years after a return is filed to assess any tax due for that year. There are a number of exceptions to this general rule, such as where a taxpayer files a false return or omits more than 25...more
Two recent cases illustrate the IRS’ ability to successfully argue that taxpayers should not benefit from their own mistakes if they result in less tax being paid. Two recent cases highlight the most current view of the...more
ALJ holds that a Retailer Must File on a Combined Basis with a Related Intellectual Property Licensing Company - A New York State Administrative Law Judge has held that a retailer must file combined corporate franchise...more