On September 9th the Department of Justice (DOJ) issued new guidance to its prosecutors aimed at encouraging more white collar criminal and civil cases against corporate executives. The new rules take effect immediately,...
The Organization for Economic Cooperation and Development’s (OECD) Base Erosion and Profit Shifting (BEPS) initiative is headed for the home stretch. Whether it will cross the finish line, however, remains to be seen....
BACKGROUND On Oct. 16, 2015, the IRS announced that its offshore compliance programs have generated $8 Billion in IR-2015-116. More than 54,000 taxpayers have participated in IRS offshore remediation disclosure...
When a taxpayer or tax professional discovers an error on a previously filed tax return, the taxpayer usually asks whether and how the error should be corrected. While there is nothing in the Internal Revenue Code or...
In the typical IRS delinquent tax return examination, the IRS agent will ask that the original delinquent returns be delivered to him or her for filing. Because providing tax returns and other information, such as...
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