On July 17th, a panel for the U.S. Court of Appeals for the Third Circuit held there is no Fifth Amendment protection for foreign bank account records. U.S. v. Chabot, No. 14-4465 (3d Cir. July 17, 2015). The...
The IRS continues to add to its list of “bad” banks, having added eight banks since June and counting. Taxpayers with undisclosed accounts at foreign banks on the list face a heightened 50-percent penalty under the...
Identity theft in which a taxpayer’s name and tax identification number are stolen and used in order to obtain fraudulent refunds continues to be a growing problem for the IRS and the victim taxpayers. In 2010, the IRS...
The IRS may be close to issuing new regulations on valuation that could significantly increase transfer tax costs. As a result, it is prudent for families who are contemplating gifts of family entity and limited partnership...
Years ago I worked with a prominent attorney, a brilliant “older statesman” now deceased. Late in his career he was lauded at a banquet held in his honor. One of the banquet speakers noted the attorney’s unusual...
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