The issue of whether to apply a new sentencing law to crimes committed before the enactment of the law has long confounded judges, both because of the recurring failure of legislatures to be clear about their intentions and because of the inherent questions of fairness that arise from the imposition of disparate sentences for the…
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IRS Business Audit Compliance Initiative Projects
The IRS regularly conducts national, regional and local compliance initiative projects (CIPs) to study suspected areas of noncompliance. The IRS uses the data from these projects to develop more comprehensive projects and allocate its audit resources to the areas showing significant noncompliance. This alert details audit initiatives focusing on business taxpayers. The projects listed are…
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Cloud Computing: U.S. Tax Compliance Complexity
In today’s technology-driven economy, many multinational enterprises are beginning to take advantage of cloud-computing technology in their global infrastructure and market facing-activities. What is cloud computing? Various definitions of clouding computing exist, perhaps the most concise is the one provided by the research firm Gartner, Inc., which calls it “a style of computing where massively…
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European and US Governments Publish Full Implementation of FATCA Agreement
The governments of the UK, France, Germany, Italy, Spain, and the US have published the full text of their reciprocal agreement to implement the US Foreign Accounts Tax Compliance Act. The agreement requires financial institutions in the five European countries to report client information to their respective tax authorities, who will then automatically forward the…
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