The IRS in news release IIR 2016-137 highlighted the accomplishments of its Offshore Voluntary Disclosure Program (OVDP) and encouraged taxpayers with undisclosed offshore accounts to come into compliance with the federal tax obligations. The OVDP and streamlined compliance programs have been used to bring over 100,000 taxpayers into compliance and have brought in over $10 billion in taxes,…
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IRS Provides Legal Advice on When Data Exchange With Foreign Countries is Confidential
In Legal Advice Issued by Associate Chief Counsel 2016-004, the IRS has given its opinion on the exact moment when information that it provides to and receives from foreign tax administrations via the Organization for Economic Cooperation and Development's Common Transmission System becomes protected under the Code's confidentiality rules. Legal Advice Issued by Associate Chief Counsel…
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Taxpayers Abilility to use Partnerships for Tax Planning Limited by the IRS' Disguised Sale Regulations
According to Law360 the Internal Revenue Service’s recently issued regulations governing the tax treatment of disguised property sales within partnerships are expected to reduce flexibility for businesses in how they manage debt and close certain tax planning avenues for managing losses and liabilities. The agency released its final rules this month, nearly three years after…
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Court Found Tax Lawyer Not Liable for Malpractice Suit Over $9.5M IRS Debt
According to Law360, An Oklahoma federal judge found insufficient evidence Thursday to keep alive a cellphone retailer's lawsuit accusing his former tax lawyer of negligently allowing a $2.1 million tax debt to balloon to $9.5 million, tossing the suit because it didn't show the outcome could have been any different. U.S. District Judge Robin J.…
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