The Supreme Court has extended the rule in Apprendi v. New Jersey, 530 U.S. 466 (2000). Apprendi held that the Sixth Amendment reserves to juries the determination of any fact, other than the fact of a prior conviction, that increases a criminal defendant's maximum potential sentence. In Southern Union Co. v. United States, 132 S.…
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Swiss Banks Giving Up Employees to IRS
Looking for leniency in tax evasion investigation, banks surrender data Thousands of employees of Swiss banks are finding that their employers are hanging them out to dry in exchange for hoped-for leniency in connection with American accounts involved in a tax evasion investigation. Bloomberg reported Thursday that several Swiss banks so far have turned over…
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FLORIDA TAX ALERT – CONVENIENCE STORES TARGETED!!!
If you have any clients in the convenience store industry, then you have probably heard that the Florida Department of Revenue has painted a state wide target on the industry. THE REASON - A belief that the industry is systematically under reporting/remitting sales tax THE AMMUNITION - Detailed information about alcohol and tobacco PURCHASES by…
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Can IRS Offshore Account Program Clean Up Domestic Tax Problems Too?
In a word, yes. In fact, you can’t be selective when amending tax returns. You can’t pick and choose what to correct. If you amend a tax return, you must fix all errors. As a corollary, if you’re coming clean in a voluntary disclosure you must clean up everythingin the tax years that are impacted.…
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