As part of the Obama administration’s announcement of a crackdown on inversions the U.S. Treasury issued final & temporary proposed regulations that would dramatically change the taxation of corporate debt issued to related corporations having nothing to do with inversions or foreign acquisitions. In a 518-page Treasury Decision, IRS has issued final and temporary regs under Code…
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No Where To Hide – Eric Bartoli Arrested In Peru Sentenced To 20 Years!
Eric V. Bartoli, who was indicted in 2003 on a 10-count indictment and has been a fugitive for more than a decade, has been arrested in Peru. Bartoli was accused of operation a large-scale ponzi scheme from 1995 through 1999. Bartoli allegedly created and operated a company by the name of Cyprus Funds, Inc.,…
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IRS Un-Resonable In Its Pursuit Of Trust Fund Penalty
According to Law360 a recent U.S. Tax Court case illustrates how aggressive the Internal Revenue Service (IRS) has become in using the trust fund recovery penalty (TFRP) to collect trust fund taxes. In Fitzpatrick v. Commissioner, T.C. Memo. 2016-199, the taxpayer was the wife of a passive investor in the employer corporation. At the request…
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Trump Presidency Could Be Death Knell For Estate Taxes!
We previously posted President-Elect Donald Trump Is Less Than Ideal for Tax Advisers? where we discussed President-Elect Trump's tax plans, which includes the repeal of the US Estate & Gift taxes. This may be a realistic possibility considering that this is in line with some of the proposals in the Republican House Ways & Means Committee Report…
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