COURT WATCH: PLANNING FOR DOMA REPEAL WITH PROTECTIVE CLAIMS FOR REFUNDS By...
A. The Windsor Case. On December 7, 2012 the U.S. Supreme Court granted the United States’ petition for writ of certiorari on the question of the constitutionality of the Defense of Marriage Act, also...
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In a recent Tax Court case a taxpayer’s charitable deduction was disallowed. Many taxpayers are interested in obtaining a charitable contribution deduction but are unsure in how to go about obtaining...
View ArticleDOJ TRIES TO CLOSE DOWN MIAMI BASED TAX-PREPARATION OFFICE BECAUSE THE...
The DOJ asked a Miami district court to shut down a Miami tax-preparation office. The suit asserts that Olivia Greene and Walter Jefferson prepared returns with falsely-claimed credits, including fuel...
View ArticleConservation Watch – Tax Court Denies Deduction for Charitable Contribution
In B.V. Belk Jr. et ux. v. Commissioner, 140 T.C. No. 1, the Tax Court, in an opinion by Judge Juan F. Vasquez, held that a couple was not entitled to a charitable deduction under § 170(h)(2)(C) of the...
View ArticleWhistleblower Basics
The Secretary of the IRS is permitted to pay such sums as he deems necessary to detect tax underpayment or to detect and bring to punishment persons who are guilty of violating the tax laws.[1] Any...
View ArticleAny Hope for Tax Reform?
Dave Camp, Republican from Michigan and House Ways and Means Committee Chair, confirmed media reports February 26 that House Speaker John A. Boehner has set aside the number one bill for use as a...
View ArticleECJ Throws Out Holland Exit Tax
The European Commission filed an infringement procedure against the Netherlands in August 2011. On January 31, the European Court of Justice (ECJ) held that the Netherlands’ rules on exit taxation...
View ArticleIRS Makes Clear The Substance-Over-Form Doctrine Is A Tool Available Only To...
In response to a September 16, 2012 letter by a taxpayer to the IRS requesting advice regarding whether a taxpayer can exploit the substance-over-form doctrine to recast a transaction, the IRS stated...
View ArticleDeutsche Bank Broker Sentenced
By Ruben Conitzer David Parse, a former CPA and broker at Deutsche Bank, was sentenced in federal court to forty-two months in prison for tax obstruction and mail fraud. The Department of Justice...
View ArticleDeferred Tax Treatment in Holland for Reinvestment of Real Estate Profits
Earlier this month the Dutch High Court ruled that a nonresident owner of real property in The Netherlands is able to place capital gains in a reinvestment reserve, permitting rollover or tax-deferral...
View ArticleForeign Real Estate Investors Beware: Buying U.S. Real Estate Comes With...
Many people visit Miami from abroad and decide it’s the perfect place to own a second home. Of course, why wouldn’t it be? It’s safe, the food and shopping are great, the beaches are beautiful and the...
View ArticleFLORIDA WOMAN’S SENTENCE TERMINATED
The Department of Justice (“DOJ”) successfully prosecuted Mary Estelle Curran, 79, for having millions of dollars in offshore bank accounts in Switzerland and Liechtenstein. Curran inherited the...
View ArticleJohn Doe Summons Issued Against First Caribbean’s U.S. Correspondent Account
The Department of Justice announced it successfully sought John Doe summons to obtain information on clients of the First Caribbean International Bank (“First Caribbean”), which is partially owned by...
View ArticleIsraeli Woman Pleads Guilty to Concealing Foreign Bank Accounts
An Israeli woman was charged in a federal court in California on Friday April 12, 2013. The woman, Guity Kashfi, signed a plea agreement and pleads guilty to conspiracy to conceal an Israeli bank...
View ArticleSection 1202 + 83(b) Elections Qualified Small Business Stock
Section 1202 of the Code provides that, “[i]n the case of a taxpayer other than a corporation, gross income shall not include 50 percent of any gain from the sale or exchange of qualified small...
View ArticleArticle 9
In a recent Tax Court case a taxpayer’s charitable deduction was disallowed. Many taxpayers are interested in obtaining a charitable contribution deduction but are unsure in how to go about obtaining...
View ArticleDOJ TRIES TO CLOSE DOWN MIAMI BASED TAX-PREPARATION OFFICE BECAUSE THE...
The DOJ asked a Miami district court to shut down a Miami tax-preparation office. The suit asserts that Olivia Greene and Walter Jefferson prepared returns with falsely-claimed credits, including fuel...
View ArticleConservation Watch – Tax Court Denies Deduction for Charitable Contribution
In B.V. Belk Jr. et ux. v. Commissioner, 140 T.C. No. 1, the Tax Court, in an opinion by Judge Juan F. Vasquez, held that a couple was not entitled to a charitable deduction under § 170(h)(2)(C) of the...
View ArticleWhistleblower Basics
The Secretary of the IRS is permitted to pay such sums as he deems necessary to detect tax underpayment or to detect and bring to punishment persons who are guilty of violating the tax laws.[1] Any...
View ArticleIrish Apples: The Common Sense Definition of a Tax Haven?
Many people have been following the Senate Permanent Subcomittee on Investigations’ inquiries into Apple’s international tax structure over the past few weeks, especially after the Senators focused...
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