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...
An attorney who represents a client in a criminal tax investigation will typically retain a forensic accountant to review and analyze the client’s financial records and tax returns mirroring the work of the IRS criminal...
The U.S. Supreme Court reversed a taxpayer’s conviction today under 26 U.S.C. § 7212(a), also known as the Omnibus Clause, which forbids “corruptly or by force or threats of force . . . obstruct[ing] or imped[ing],...
On March 13, 2018, the Internal Revenue Service (IRS) announced that it will terminate its 2014 Offshore Voluntary Disclosure Program (OVDP), effective September 28, 2018. Since its launch in 2009, over 56,000 taxpayers have...
In prior blog posts (here) and (here), we discussed IRS efforts to combat what it considers to be abusive conservation easement deductions. In Notice 2017-10 (here), the IRS warned that certain conservation easement...
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