Resources

In a prior blog post (here), we discussed IRC Section 7345 which allows the IRS to take actions to either revoke or deny a passport to a taxpayer with a seriously delinquent tax debt. On April 5, IRS Chief Counsel...

Josh Ungerman was quoted in the Bloomberg Law 81 DTR (BNA) 12 article, “Pharma CEO ‘Reckless’ in Not Disclosing Swiss Account: Government.” Please click here to read the article.

Josh Ungerman was quoted in the April 23, 2018 TaxNotes article, TNT 78-4, “Group Still Pushing to Move CI to Treasury.” Click here to read the article.

In a criminal tax investigation, the IRS generally must prove a taxpayer either underreported his income or overstated his deductions. To do so the IRS uses a number of methods of proof that fall under one of two categories:...

At the heart of the new §199A deduction is a series of tentative deductions separately determined for each trade or business in which the taxpayer owns an interest based on 20% of qualified business income...