The Swiss parliament’s upper house gave its approval to proposed amendments to a new U.S.-Swiss double taxation treaty that would make it easier for U.S. authorities to seek information on secret bank accounts held by U.S. taxpayers with Swiss banks. The Council of States, the Swiss equivalent of the U.S. Senate, approved the amendments by a…
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IRS Will Not Acquiesce on Tax Court's Fraud Finding in ‘Norris'
The Internal Revenue Service announced in Action on Decision 2011-05 that it will not acquiesce on a U.S. Tax Court finding that, after weighing each of the 11 badges of fraud equally, the service did not establish taxpayers' intent to fraudulently evade taxes. In Norris v. Commissioner, T.C. Memo. 2011-161, the Tax Court found that…
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Estate Taxes – As Filing Deadline Approaches it Create Challenges for Form 8939.
Executors filing the Internal Revenue Service's Form 8939 to elect into the modified carryover basis regime for people who died in 2010 must file the form as completely as possible, keeping in mind that amendments are limited. You've got one chance to get this thing right and you have a do-over within six months, but…
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Whistleblower Can Remain Anonymous During Litigation
The U.S. Tax Court, in an issue of first impression, said Dec. 8 that a whistleblower can remain anonymous in court proceedings prosecuting a whistleblower claim in order to protect the former executive's privacy concerns while serving as a confidential informant (Whistleblower 14106-10W v. Commissioner, T.C., No.14106-10W, 137 T.C. No. 15, 12/8/11). Judge Michael Thornton…
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