Searching Content by Sanpreet (Sunny) Dhaliwal ordered by Published Date Descending.
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As End Looms, IRS Offshore Voluntary Disclosure Program Processing Delays Create Additional Risk For Participants
As we noted previously, the IRS announced in March that it will end its Offshore Voluntary Disclosure Program (OVDP) on September 28, 2018. Under OVDP, a taxpayer with undisclosed foreign assets or income...
United States
17 Jul 2018
IRS Issues Final Regulations On BBA Partnership Audit Regime
The IRS has issued final regulations regarding the new centralized partnership audit regime, referred to as the BBA regime.
United States
5 Jan 2018
Substantial Changes To Partnership Tax Audit Procedures Will Severely Impact Partner Liability And Rights Before the IRS
These rules are a significant departure from the old rules, known as "TEFRA", which administered a tax deficiency at the individual partner level.
United States
26 Sep 2017
Tax Court Disallows A $33 Million Charitable Donation Deduction Because Taxpayer Did Not Sufficiently Fill Out Form
Serving as a vivid reminder that it is vital that a taxpayer comply strictly and completely with the charitable deduction regulations, the Tax Court recently denied a $33 million charitable deduction...
United States
17 Jul 2017
Supreme Court Agrees To Review Sweeping Tax Obstruction Of Justice Decision
In a decision that could have far reaching consequences in both the civil and criminal tax realms, on June 27th, the U.S. Supreme Court agreed to review the conviction of Carlo Marinello...
United States
12 Jul 2017
IRS Urges Partnerships To Amend Partnership Agreements To Address Expanded Role Of Partnership Representatives
The new partnership audit regime, enacted as part of the Bipartisan Budget Act of 2015 ("BBA"), allows the IRS to assess and collect unpaid tax at the entity level, rather than from individual partners.
United States
29 Jun 2017
Leak Of 1.3 Million Files From Bahamas Corporate Registry Provides Yet Another Starting Point For Government Investigations
Five months after the Panama Papers leak of offshore client files, the ICIJ have released data from the corporate registry in the Bahamas pertaining to approximately 1.3 client million files.
United States
10 Oct 2016
IRS Seeks To Speed Up FATCA Reporting With Imposition Of Year End Deadline To Finalize IGAs
The Foreign Account Tax Compliance Act ("FATCA") was enacted in 2010 by Congress to target non-compliance by U.S. taxpayers using foreign accounts.
United States
9 Aug 2016
Tax Court Finds Predictive Coding Satisfies Reasonable Inquiry Standard For Responding To Discovery Requests
The IRS and Petitioners had agreed that Petitioners would run a search for terms determined by the IRS on the potentially relevant documents.
United States
28 Jul 2016
IRS On Alert Of Partners Attempting To Slip Through The Cracks Before New Partnership Audit Regime Takes Effect
The IRS expressed its intention to watch for partners exiting partnerships to avoid tax, during a District of Columbia Bar event on June 23, 2016.
United States
6 Jul 2016
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