We originally posted on November 17, 2014, Luxemburg Leaks’ causes ‘Tax storm’ of government, media response Public officials across the globe reacted with swift condemnation and calls for reform following ICIJ’s investigation into secret tax deals between Luxembourg and hundreds of international corporations. The New York Times said the revelations have sparked a “rising furor” in…
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Selling PwC Partner Could Not Use Installment Method for Unrealized Receivables
A former PwC partner couldn't use the installment method to account for proceeds from unrealized receivables in the sale of her PwC partnership interest (Mingov. Commissioner, 5th Cir., 13-60801, 12/09/14). The U.S. Court of Appeals for the Fifth Circuit affirmed late Dec. 9 a U.S. Tax Court ruling that Lori Mingo wasn't entitled to use…
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IRS Supplies Guidelines Used for Conducting the OVDP Program – Pursuant to a FOIA Request!
Are you still wondering how the IRS will perceive your clients OVDP filing, with your associated requests for lower penalties or with some other legal tax position regarding your client, which is based upon relevant legal precedent? Well wonder no longer, as one of our colleagues, the Brager Tax Law Group, requested the IRS's documents…
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FATCA Update! – 101 FATCA Agreement To Date!
The IRS released Announcement 2014-38 which provides guidance with respect to jurisdictions that are treated as if they had a FATCA intergovernmental agreement (IGA) in effect pursuant to Announcement 2014-17, 2014-18 I.R.B. 1001, but that do not sign the IGA before December 31, 2014. Announcement 2014-38 provides that a jurisdiction that is treated as if…
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