According to Law360, Swiss bank Zürcher Kantonalbank has agreed to pay $98.5 million after admitting to helping U.S. clients dodge taxes by letting them stash money in undeclared accounts that used code names and shell companies, Manhattan federal prosecutors announced on August 13, 2018. ZKB will hand over the amount as part of a deferred prosecution…
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IRS Prop Regs on 20 % Deduction for Passthrough Businesses
The Internal Revenue Service issued proposed regulations on August 8, 2018 for a new provision allowing many owners of sole proprietorships, partnerships, trusts and S corporations to deduct 20 percent of their qualified business income. The new deduction, referred to as the Section 199A deduction or the deduction for qualified business income, was created by…
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IRS Win In Altera Cost-Sharing Row Withdrawn?
On July 24, 2018 we posted IRS Cost-Sharing Regulations Revived By Appeals Court where we discussed that the Ninth Circuit reversed a decision by the U.S. Tax Court that invalidated an Internal Revenue Service cost-sharing regulation in a dispute with an Intel Corp. subsidiary, saying the revenue agency did not exceed its authority in promulgating the…
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Court of Claims Rejects Colliot & Wadhan: Willful FBAR Penalty Not Limited to $100,000
On July 27, 2018 we posted 2nd Taxpayer Victory on a FBAR Penalty Case - FBAR Limited to $100M! where we discussed US v. Dominique G. Colliot, case number 1:16-cv-01281, in the U.S. where a District Court for the Western District of Texas how that the maximum FBAR penalty was limited to $100,000 a year. We also discussed…
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