In 2016, there was a clear upward trend in the fight against tax evasion globally. The April 2016 release of the Panama Papers caused an international shake-up that resulted in multiple global tax evasion investigations and regulatory reviews including in the British Virgin Islands, Singapore, Hong Kong, France, Spain, Germany, Australia, Austria, Sweden and the Netherlands. The…
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Tax Court May Determine Negligence Penalty Where Partner Omits Partnership Item.
The Tax Court has held that, where a partner omits a partnership item from his individual tax return, and the partnership itself was subject to a TEFRA audit, the Court has jurisdiction to determine that partner's resulting negligence penalty. The Tax Court's jurisdiction generally is limited to the review of deficiencies asserted by IRS (and…
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IRS Releases its SOI Tax Stats on Controlled Foreign Corporations (CFCs)
The IRS has posted its tables entitled Controlled Foreign Corporations, Tax Year 2012, which consists of two new tables presenting data from Form 5471, Controlled Foreign Corporations, and Form 8858, Information Return of U.S. Persons With Respect to Foreign Disregarded Entities,which are now available on SOI’s Tax Stats Webpage. The tables present data from the…
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OECD Targets CRS Avoidance Schemes With Over 1800 Relationships to Automatically Exchange CRS Information
The OECD's Centre for Tax Policy launched a disclosure facility for reporting schemes that aim to circumvent the internationally agreed Common Reporting Standard (CRS) for automatic exchange of taxpayers' account information. The disclosure facility, which can be accessed through the Automatic Exchange Portal, is part of a three step process the OECD has created to…
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