Violations of non-tax laws—including those enforced by the Internal Revenue Service—cannot form the basis of a whistleblower award under tax code Section 7623, the IRS Office of Chief Counsel said in a program manager technical advice memorandum. This memorandum (PMTA 2012-10 ) addresses whether I.R.C. § 7623 authorizes payment of whistleblower awards based on information…
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District Court – Bankruptcy Court Cannot Enjoin IRS's Future Exercise of Rights to Setoff & Recoupment
The U.S. District Court for the Eastern District of New York ruled Sept. 15, 2012, that A bankruptcy court has no jurisdiction to enjoin the Internal Revenue Service's future exercise of its rights to setoff and recoupment. Relivant portions of the Decision … VI. Recoupment and Setoff The final dispute at issue in this…
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Tax treaties hurt Credit Suisse
CREDIT Suisse could see clients in western Europe withdraw up to a net $37bn (£23bn) in the next few years as Switzerland bows to pressure to stop foreigners using secret offshore accounts to evade taxes. Swiss bank secrecy has come under heavy pressure in recent years as cash-strapped governments have sought to fight tax evasion.…
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Prop. Regs Would Withdraw Onerous Covered Opinion Rules and Modify Disclaimer Rules
Prop. Regs Would Withdraw Onerous Covered Opinion Rules and Modify Disclaimer Rules in Circular 230 Under the rules in Circular 230, which govern tax practice before the IRS, tax practitioners must meet minimum standards of conduct with respect to written tax advice, and those who do not are subject to disciplinary action, including suspension or…
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