Resources

At least once in their career most tax return preparers have faced the dilemma of whether and how to make a disclosure with a tax return. A disclosure is an extra explanation beyond the usual income and expenses shown on a...

Josh Ungerman was quoted in the Tax Notes article, “First Charges Announced for Bad Entry Into OVDP Alternative.”

Most LLC agreements provide that distributions will be made to members in accordance with their positive capital accounts. In fact it is virtually boilerplate.  So what happens when an LLC makes a Subchapter S election...

The IRS Streamlined Procedures are not a one-size-fits-all program, as evidenced by the successful criminal indictment of a taxpayer charged with filing a false “streamlined submission” to disclose his foreign accounts...

Many taxpayers have begun to receive a letter from the IRS stating that the IRS intends to contact other persons—including potentially the taxpayer’s neighbors, banks, employers, and employees—about the taxpayer’s tax...