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Yearly Archives: 2017

Treasury Expanding Magnitsky Act as a Basis for Applying Sanctions

According to DiazReus, as of December 2017, the United States Treasury Department’s Office of Foreign Asset Control (“OFAC”) will begin using an expanded version of the Magnitsky Act as a basis for applying sanctions to individuals and entities suspected of corruption related activities.   The Magnitsky Act, formally known as the Russia and Moldova Jackson–Vanik Repeal and…
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Senate Passes $1.4 Trillion Tax Cut Legislation

According to Law360, The U.S. Senate passed an expansive tax cut bill early Saturday that is projected to add more than $1 trillion to the deficit, after garnering enough support from faltering and fiscally conservative Republicans. The Tax Cuts and Jobs Act, or H.R. 1, passed by a vote of 51-49, with Sen. Bob Corker, R-Tenn.,…
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Will Marinello Be The McDonnell Of Tax Crimes?

According to Law360, Carlo Marinello will argue to the U.S. Supreme Court next month that a vague tax law gives prosecutors power to criminalize anything that makes the IRS' job harder, in a case that could see the high court continue limiting broad criminal laws as it did last year in U.S. v. McDonnell. Marinello was…
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Partner-Level CDP Case Can Be Revied by the Tax Court

The Tax Court in McNeill, 148 TC No. 23 (2017), held that it has jurisdiction under Section 6330(d)(1) to review a notice of determination when the underlying tax liability consists of a penalty relating to an adjustment to a partnership item excluded from deficiency procedures by Section 6230(a)(2)(A)(i). The taxpayer was a partner in a…
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