The Tax Court determined that an advance from a U.K.-based utility to its wholly owned partnership in connection with the partnership's acquisition of a U.S. utility company was a loan, not a capital contribution. Accordingly, the $932 million of payments made on loan notes was deductible by the partnership as interest. Acknowledging that the advance…
Read more
Tax Court upheld the denial of Installment Agreement where Taxpayer was Not Compliant
The U.S. Tax Court upheld the denial July 24 of an installment agreement in a collection action against a Louisiana chiropractor for liabilities relating to 2006 and 2007 (Pace v. Commissioner , T.C., No. 9216-11L, T.C. Memo. 2012-211,7/24/12) The Taxpayer operated a chiropractic business through his wholly owned corporation, Dauntless, Inc. (Dauntless). Taxpayer filed his…
Read more
Tax Cheats May Claim IRS Whistleblower Rewards?
Recently, former UBS banker Bradley Birkenfeld was awarded $104 million for being a UBS informant. The IRS award is the biggest and only sizable award in the much discussed program. It’s making many whistleblowers more alert and more claims are on the way. However, Birkenfeld was not free of all wrongdoing. In fact, although his lawyers were…
Read more
Channel Islands begin FATCA negotiations
The governments of Jersey, Guernsey and the Isle of Man have jointly announced the start of negotiations with the US to ease implementation of the Foreign Accounts Tax Compliance Act (FATCA). FATCA requires foreign banks to report the affairs of their American clients to the US Internal Revenue Service and apply financial sanctions for…
Read more
