TAXLITIGATOR Blog

Posted by Hochman Salkin Toscher Perez P.C. Posted on Tuesday, September 02, 2014

AGOSTINO & ASSOCIATES –To download a few great articles prepared by our very close friends at the Law Firm of Agostino & Associates in Hackensack, NJ ( www.agostinolaw.com ), see the Agostino & Associates Newsletter https://doc-0g-a0-apps-viewer.googleusercontent.com/viewer/secure/pdf/3nb9bdfcv3e2h2k1cmql0ee9cvc5lole/a2e9d5ia6l9d8arb24i9qe55u5g1r2jr/1409675775000/drive/*/ACFrOgB3DcF0a_jTmvIpYCiuNKqO7L9fgn3s-OoYgXI80f841xzDJ5w3W4RQJIos9LXs1ctCT2z8v3FIziSDS2y-W6ct63hwuBzvEW_vnXAgbmb31pJpOwZuVMW1Ou8=?print=true DE NOVO REVIEW OF ASSESSABLE INTERNATIONAL PENALTIES By Frank Agostino, Brian D. Burton, and Lawrence A. Sannicandro    – Many taxpayers and […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Tuesday, August 26, 2014

All tax planning is not to be condemned. “It is no surprise that a knowledgeable tax attorney would use numerous legal entities to accomplish different objectives. This does not make them illegitimate. Unfortunately such ‘maneuvering’ is apparently encouraged by our present tax laws and codes.” [1] CIRCULAR 230 – Cir. 230 provides the regulations governing […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Wednesday, August 20, 2014

Has this happened to you? You are in your office toiling away in the tax trenches when a colleague down the street who works the offshore cases sends you an e-mail: “I’m sending over an OVDP client. He has a problem and I can’t represent him anymore.” Eventually the client sits in your office and […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Tuesday, August 12, 2014

Historically, IRS examiners were assigned to audit taxpayers in many different industries. On one day, an examiner audited a grocery store and on the following day the examiner may have audited a computer retailer or a medical doctor. As a result, experience gained in one audit did not significantly enhance the examiner’s experience for purposes […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Friday, August 08, 2014

The IRS recently announced Streamlined Filing Compliance Procedures in an effort to encourage U.S. taxpayers to come into compliance with their reporting and filing requirements associated with varying interests in foreign financial accounts and assets.[i] The streamlined procedures require the filing of original or amended tax returns reporting not only for whatever foreign source income […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Tuesday, August 05, 2014

There are various audit and investigative techniques available to corroborate or refute a taxpayer’s claim about their business operations or nature of doing business. IRS audit or investigative techniques for a cash intensive business might include an examiner determining that a large understatement of income could exist based on return information and other sources of […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Thursday, July 31, 2014

The Internal Revenue Manual (IRM) contains a Penalty Handbook intended to serve as the foundation for addressing the administration of penalties by the IRS. It is the “one source of authority for the administration of penalties. . .”[1] and provides a “fair, consistent, and comprehensive approach to penalty administration.” As such, the IRM is often […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Wednesday, July 02, 2014

The IRS recently announced Streamlined Filing Compliance Procedures in an effort to encourage U.S. taxpayers to come into compliance with their reporting and filing requirements associated with varying interests in foreign financial accounts and assets. The streamlined procedures require the filing of original (for non-residents) or amended (for residents) tax returns. Such tax returns must not […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Thursday, June 26, 2014

The IRS recently announced an expansion of the streamlined filing compliance procedures announced in 2012 and important modifications to the 2012 Offshore Voluntary Disclosure Program (OVDP). For eligible taxpayers residing outside the U.S., the revised Streamlined Filing Compliance Procedures provide that all penalties will be waived. For eligible taxpayers residing in the U.S., the revised […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Tuesday, June 24, 2014

The Internal Revenue Service recently announced significant changes in IR-2014-73[i] regarding their offshore voluntary compliance programs, providing new options to help both resident and non-resident U.S. taxpayers whose failure to disclose their offshore financial accounts was non-willful. The expanded 2014 streamlined procedures are available to a wider population of U.S. taxpayers living outside the country and, […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Sunday, June 22, 2014

U.S. taxpayers with previously undisclosed interests in foreign financial accounts and assets continue to analyze and seek advice regarding the most appropriate methods of coming into compliance with their U.S. filing and reporting obligations. Many are pursuing participation in the IRS offshore voluntary disclosure program (the OVDP, which began in 2012 – modeled after similar […] Read More…

Posted by Hochman Salkin Toscher Perez P.C. Posted on Thursday, June 19, 2014

The Internal Revenue Service announced major changes in IR-2014-73 regarding their offshore voluntary compliance programs, providing new options to help both taxpayers residing overseas and those residing in the United States. The changes are anticipated to provide thousands of people a new avenue to come into compliance with their U.S. tax obligations. The changes include […] Read More…