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IRS Targeting Post-Voluntary Disclosure Compliance With New Campaign
Recently, the IRS announced that it was targeting individual taxpayers who previously participating in its Offshore Voluntary Disclosure Program
United States
29 Jul 2019
Denver-Based Court Of Appeals Issues Two Important Cannabis Rulings
In the last few week, the Denver-based United States Court of Appeals has issued two decisions important to Colorado's burgeoning cannabis industry.
United States
21 May 2019
IRS Announces Five New Campaigns
Yesterday, the Large Business and International Division ("LB&I") of the IRS announced five new compliance campaigns. This is on top of the 35 previously announced campaigns and discussed here.
United States
20 Jul 2018
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 Announces Six New Campaigns
Yesterday, the Large Business and International Division ("LB&I") of the IRS announced six new compliance campaigns. Faced with continued budget cuts ...
United States
24 May 2018
Did Congress Unexpectedly Deny Healthcare Providers A Deduction For Billions In Medicare Overpayments? Maybe.
Before tax reform, under 162(f), a payment to the government for a violation of the law was deductible unless it was a fine or penalty.
United States
22 May 2018
IRS To End Offshore Voluntary Disclosure Program In September
The IRS has announced that it will begin winding down its Offshore Voluntary Disclosure Program (OVDP) on September 28, 2018.
United States
19 Mar 2018
Eleventh Circuit Holds That Taxpayer's Affidavit Can Defeat Summary Judgment
In litigation, the IRS will often seek to short circuit a proceeding by filing an early, pre-discovery motion for summary judgment. Taxpayers, in turn, often resist those motions ...
United States
8 Feb 2018
Who Qualifies As A Partner Under The New BBA Regulations
This is the first of a series of deeper dives into the newly finalized partnership audit regulations that cover who can elect out of the new centralized partnership audit regime.
United States
12 Jan 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
Update On Tax Reform
The more-or-less final version of the tax reform bill is here and Congress is expected to vote on it this week.
United States
20 Dec 2017
Tax Reform Is Here
Dentons is covering all of the latest news on the various tax reform plans that the United States Congress is currently considering.
United States
16 Nov 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
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