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WEBINAR featuring Steven Toscher and Michel Stein – New IRS Scrutiny of Cryptocurrency Reporting: Filing Requirements and Exchange Treatment

New IRS Scrutiny of Cryptocurrency Reporting: Filing Requirements and Exchange Treatment Strafford  February 15, 2018 – 10:00 a.m. – 11:30 p.m. (Pacific) On February 15 Steven Toscher and Michel Stein will be hosting a Strafford Webinar “New IRS Scrutiny of Cryptocurrency Reporting: Filing Requirements and Exchange Treatment”   The panel will provide tax counsel, accountants and other advisers with … Continue reading WEBINAR featuring Steven Toscher and Michel Stein – New IRS Scrutiny of Cryptocurrency Reporting: Filing Requirements and Exchange Treatment

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WEBINAR featuring Michel Stein – FBAR 2018 Update: Mastering FinCen Form 114, Deadlines, Extension, Penalty Resolution and Waiver Provisions

FBAR 2018 Update: Mastering FinCen Form 114 Deadlines, Extension, Penalty Resolution and Waiver Provisions Strafford  February 1, 2018 – 10:00 a.m. – 11:50 p.m. (Pacific) On February 1 Michel Stein will be hosting a Strafford Webinar “FBAR 2018 Update: Mastering FinCen Form 114, Deadlines, Extension, Penalty Resolution and Waiver Provisions”  The IRS announced more changes to the filing requirements … Continue reading WEBINAR featuring Michel Stein – FBAR 2018 Update: Mastering FinCen Form 114, Deadlines, Extension, Penalty Resolution and Waiver Provisions

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Tax Court to IRS: You’re Too Late Baby! by Robert S. Horwitz

As part of its crackdown on taxpayers who were not reporting income from overseas assets, in 2010 Congress enacted Internal Revenue Code sec. 6038D. That section requires a taxpayer to provide information about “specified foreign financial assets.”  It applies to tax years beginning after March 18, 2010.  The IRS developed Form 8938, Statement of Specified … Continue reading Tax Court to IRS: You’re Too Late Baby! by Robert S. Horwitz

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IRS’s FY 2017 Annual Report Blog #1: The IRS Appropriately Resets Its Criminal Priorities by Evan J. Davis

This is the first in a series of blogs that will analyze the IRS’s Fiscal Year 2017 Annual Report. This blog will focus on the shift away from easy cases in favor of harder cases such as foreign-account and hidden-income cases that most consider the core of IRS criminal enforcement. Later blogs will take a … Continue reading IRS’s FY 2017 Annual Report Blog #1: The IRS Appropriately Resets Its Criminal Priorities by Evan J. Davis

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Planning an Overseas Vacation? First Pay Your Taxes By Robert S. Horwitz

If you’re planning a vacation overseas in 2018 and you owe more than $50,000 in taxes, penalties and interest to the IRS, you have another thing coming. Beginning January 2018 the IRS will start implementing Internal Revenue Code section 7345.  That section was enacted in December 2015.  It says “If the Secretary receives certification by … Continue reading Planning an Overseas Vacation? First Pay Your Taxes By Robert S. Horwitz

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WEBINAR featuring Steve Toscher – The Perils of Civil and Criminal Tax Penalties: What You Need to Know

The Perils of Civil and Criminal Tax Penalties: What You Need to Know The Knowledge Group   January 11, 2018 – Noon – 1:30 pm (Pacific) On January 11 at Steve Toscher, Curtis Elliott, Jr. and Steve Mather will be hosting a Knowledge Group Webinar “The Perils of Civil and Criminal Tax Penalties: What You Need to Know.” The Internal … Continue reading WEBINAR featuring Steve Toscher – The Perils of Civil and Criminal Tax Penalties: What You Need to Know

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Is It Debt? Is It Equity? Let the Tax Court Decide by Robert S. Horwitz

A question that frequently arises in tax cases is whether a transaction is debt or equity. As Judge Alex Kosinski recently noted in Hewlett-Packard, Inc. v Commissioner, Dkt. 14-73047 (9th Cir., Nov. 14, 2016), https://cdn.ca9.uscourts.gov/datastore/opinions/2017/11/09/14-73047.pdf, it is a “timeless and tiresome question of American tax law”.  In arriving at the answer, which was “we defer to the … Continue reading Is It Debt? Is It Equity? Let the Tax Court Decide by Robert S. Horwitz

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IRS Complex Collection – Holiday Considerations and Collection Moratorium by Cory Stigile

As the holidays approach, it is a great time to think about your clients who have had difficulty paying their taxes. Below is a Top 5 list of enforced collection issues to think about this December. Collection Moratorium / Current Compliance – Although it is not an official policy position, during most of December the … Continue reading IRS Complex Collection – Holiday Considerations and Collection Moratorium by Cory Stigile

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Court Tightens Noose on Reasonable Cause Exception for the FBAR Penalty by Robert S. Horwitz

A U.S. person with foreign financial accounts worth over $10,000 during the calendar year is required to file a Foreign Bank Account Report (FBAR). Failing to file can result in either a “non-willful” or a “willful” penalty under 31 USC §5321(a)(5).  If the failure is non-willful, the person can avoid liability under the reasonable cause … Continue reading Court Tightens Noose on Reasonable Cause Exception for the FBAR Penalty by Robert S. Horwitz

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IRS Can’t Assess Interest and Penalties on Criminal Restitution by Robert S. Horwitz

A defendant convicted of a tax crime can be ordered by the district court to pay the IRS restitution equal to the amount of the tax loss. As part of the 2010 Firearms Excise Tax Improvement Tax, Congress added sec. 6201(a)(4) to the Internal Revenue Code.  That section authorizes the IRS to “assess and collect … Continue reading IRS Can’t Assess Interest and Penalties on Criminal Restitution by Robert S. Horwitz

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Tax Court Update: What is a Postmark? by Jonathan Kalinski

My colleagues and I have spent hours discussing the best way to mail time sensitive documents such as a Tax Court petition, tax return, and refund claim. FedEx or U.S. Postal Service, Certified Mail or Overnight or Personally Stamped Green Card[i] or not.  Consider this the tax lawyer equivalent of Brady or Manning (Brady), The Beatles … Continue reading Tax Court Update: What is a Postmark? by Jonathan Kalinski

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Beware of California Penalties for Failure to Report Foreign Financial Assets on Form 8938 by Michel Stein

The California Franchise Tax Board (“FTB”) recently reminded the public that the State of California (“State”) can and will impose penalties for failing to disclose foreign financial accounts and assets.  In State Legal Ruling 2017-02 (October 16,2017), the State considered whether its conformity to federal information filing requirements relating to foreign financial assets imposed by … Continue reading Beware of California Penalties for Failure to Report Foreign Financial Assets on Form 8938 by Michel Stein

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