a

Published in on February 12, 2018 We welcome back guest blogger Stuart J. Bassin who writes about a topic recently on everyone’s mind, the government shutdown. Whether you are a government employee who must spend endless hours at the water cooler discussing whether you will come to work or someone impacted by the shutdown or threat of

Read More

We all know the talking points underlying the corporate tax reform provisions in the recent tax legislation. We were told that corporations were taxed at a roughly 35 percent rate, that tax reform would reduce corporate tax liabilities, and that the reform would make billions available for new projects to boost the economy.   Now that

Read More

In recent years, transfer pricing issues have been a major priority for IRS audits.  While the IRS has made headlines by bringing a number of big-dollar cases against large multi-nationals, the courts have not been impressed.  Within the past few years, the IRS has lost a number of major transfer pricing cases.  Many of those

Read More

December 26, 2017 by Stuart Bassin You have probably heard that one “feature” of the new tax law is its treatment of deductions for state and local taxes.  To simplify, under the new law, deductions for state and local taxes (both income and property) are generally limited to $10,000, beginning in 2018.   For those of us

Read More

October 17, 2017 Today we welcome back guest blogger Stu Bassin for his take on the argument in the Altera case. Stu has blogged with us on several occasions. Because of the importance of the case, we are providing two views of the argument in Altera today. Keith The Ninth Circuit held the long-awaited argument

Read More

Daily Tax Report Tuesday, October 10, 2017 Tax Audits: A Ban on Outside Lawyers in IRS Audits Is Past Due, Lawyers Say By Alison Bennett The possibility of a Treasury Department proposal to keep private-sector counsel out of tax examinations is getting mixed reviews. The idea, announced in an Oct. 4 report, calls attention to

Read More

Ex-Arthur Andersen Exec Sues IRS After Tax Shelter Fight By Jimmy Hoover Law360, Washington (August 25, 2017, 5:51 PM EDT) — A onetime executive of defunct accounting firm Arthur Andersen LLP has sued the IRS for legal fees after he fought off its $1.6 million penalty over alleged tax-shelter promoting in the late 1990s, saying

Read More

“Enrolled agents” are tax specialists authorized by the IRS to represent taxpayers in tax disputes in many of the same ways as tax attorneys and CPAs.  To obtain an “enrolled agent” designation, an applicant must pass an IRS competency examination.  Earlier this month, the IRS issued a regulation massively increasing the user fee applicants must

Read More

Wells Fargo Decision Answers Economic Substance Question Practitioners have debated the parameters of the economic substance doctrine for decades. A recent district court opinion in Wells Fargo & Co. v. United States, No. 09-CV-2764 (D. Minn. May 24, 2017), addressed and resolved one of the more interesting undecided questions regarding the relationship of the so-called objective

Read More

Tax Shelters Side Effect of ACA Repeal Could Include Tax Shelters Snapshot  Economic substance doctrine change could make pro-tax shelter argument stronger  Tax shelter use has been on decline as IRS has gone after “abusive” transactions By Laura Davison The U.S. government would have a tougher time shutting down tax shelters if congressional Republicans successfully repeal

Read More