By way (once again) of Paul Caron (emphasis is mine): Smith: The APA’s Reasoned-Explanation Rule and IRS Deficiency Notices Patrick J. Smith (Ivins, Phillips & Barker, Washington, D.C.), The APA’s Reasoned-Explanation Rule and IRS Deficiency Notices, 134 Tax Notes 331 (Jan. 16, 2012): The D.C. Circuitâs confirmation in Cohen that the Administrative Procedure Act (APA) applies to [...]
The AP reports that the IRS has continued to allocate more of its resources to the examination of the tax returns of the super rich: One in eight people earning at least $1 million annually was audited by the Internal Revenue Service last year, making them far likelier to be examined than those making below $200,000, [...]
The Treasury Inspector General for Tax Administration says the IRS needs to improve the quality of its audits of small corporations. Listen: TIGTA reviewed whether IRS examiners followed proper procedures and guidelines when auditing the returns of small corporations. The IRS defines small corporations as corporations with assets of less than $10 million. Many corporations in the [...]
Taxpayers and their advisors have good reason to want to categorize losses as theft losses rather than investment losses. Theft losses are treated as ordinary losses and are deductible in full in the year incurred. Investment losses are treated as capital losses and are limited to the amount of capital gains plus $3,000. It is, therefore, not surprising [...]
I hope everyone had a great Thanksgiving. With the holidays upon us, our attention shifts to spending more quality time with family and friends. As you take time off at the end of the year, it can be a great opportunity to do a little preparing for the new tax season just aroundthe corner. The first order of business should be to protect your important documents by completing the
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Accounting Today reports that one of Switzerlandâs oldest banks, Clariden Leu, has become the latest to cooperate with U.S. tax authorities in disclosing the names of American investors: The bank has begun notifying some of its U.S. customers that it plans to reveal their names and account information to the Internal Revenue Service, according to [...]
WebCPA reports that the IRS increased the number of fraudulent tax refund claims it detected and stopped during the 2011 tax-filing season by 171 percent over the previous year: As of April 30, 2011, the IRS had identified 775,723 tax returns with $4.6 billion claimed in fraudulent refunds and prevented the issuance of $4.4 billion, [...]
Fortunately, the Milwaukee Brewers surprising loss to the St. Louis Cardinals in the National League Championship Series has not blurred Milwaukee lawyer and blogger Brian Mahany‘s judgment in tax matters.¹ Mahany, proprietor of the law blog, Due Diligence, gives some excellent advice to prospective offshore investors in Looking to Evade Taxes? There are Still Plenty of People Willing to [...]
I just googled “IRS audit of Google” and found this blog post by Paul Caron: Bloomberg, Google Tax Probe to Focus on Offshore Units, by Jesse Drucker: The IRS is auditing how Google avoided federal income taxes by shifting profit into offshore subsidiaries, according to a person with knowledge of the matter. The agency is [...]
Last year I wrote a post titled IRS Disbars CPA for Relying on Client’s Income and Expense Numbers about a disturbing trend by the IRS to draft private tax preparers and force them to work as IRS auditors without pay. Here’s what I said: Tax preparers are advocates for their taxpayer clients and do not work for the IRS. Even [...]
The IRS revealed last week a new program where business owners, particularly those that own small businesses, need to reclassify contractors as employees and make a small payment to cover past payroll taxes. The article Price of Reclassifying Workers, written by Sarah E. Needleman and Emily Maltby comes after an ultimatum by the IRS for small businesses (which tend to have less staff and a looser structure): raise operating costs
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Jack Townsend has an excellent post today (all of his posts are excellent) about C corporation constructive dividends. In United States v. Ellefsen, ___ F.3d ___, 2011 U.S. App. LEXIS 18684 (8th Cir. 2011), the appeals court addressed the issue of whether the IRS properly reclassified payments made by a C corporation to a trust, [...]
The IRS is apparently so happy with the results of it’s offshore voluntary disclosure program that it has established a similar program in the area of worker classification. Michael Cohn of AccountingToday writes that the IRS has introduced a new voluntary compliance program Wednesday to convince employers to resolve their past issues with classifying employees as independent [...]
Todayâs Tax Resolution Tip:
Once you file your yearly tax return, you might be tempted to get rid of all the receipts, forms, calculations and documentation lying around on your living room floor or home office. However, it is important you keep your tax documents for each taxreturn for at least 7 years. Copies of your tax return should be kept indefinitely.
Your tax returns do not disappear once you file them.
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The tax gap – the difference between what taxpayers’ should pay to the IRS every year and what they actually pay – is estimated to be about $300 billion a year. Karen Hube writing for the Washington Post confirms what we have reported here: The IRS is stepping up its enforcement activities (emphasis is mine): [...]
Being audited by the IRS can be a scary and stressful situation. Whether you are being audited for tax problems from investment mishaps, offshore accounts or any other reason, it is important to make sure a tax professional is there to make your audit goes as smoothly as possible. Karen E. Klein of the LA Times offers great advice to a reader about to be audited:
Karen: You answered a question
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I recently came across a post on The Global Resolution from the Thorn Law Group. The Global Resolution is the agreement the U.S. government and European banks are currently working on in a continued effort to put a stop to offshore tax evasion.
How will it work:
1) Any foreign bank under U.S. investigation will pay a fine to the government
2) Said bank will disclose U.S. client names to the government
3) U.S. government
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Michael Jackson’s former manager is facing some major IRS tax problems. Raymone Bain was charged on two counts of failure to file tax returns from 2006 – 2008 despite large earnings from working for the star as his general manager and spokeswoman during that period.
Bainpleaded guilty on Wednesday, June 22 for failing to file both federal and District of Colombia returns. She is scheduled for sentencing on August 13,
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The Blog of the Legal Times reports of a man who sued the IRS because it would not audit his company’s tax returns:
Guess?, Inc. co-founder Georges Marciano has lost his bid in Washington federal court for an order forcing the IRS to investigate his tax returns and liabilities.
Marciano had argued that the audit could reveal money [...]
“The funny thing is, I was an honest man, straight as an arrow. I had to come to prison to be a crook.”
 - Andy Dufresne, Shawshank Redemption -
WebCPA reports that an inmate in a New Jersey prison has pleaded guilty to bilking the IRS out of nearly $215,000 by filing false taxreturns for his jail mates:
Jerry [...]