Taking A Cooperative Approach To Your Legal Issues
We are pleased to republish with permission, the Tax Analysts article below written by Charles Bruce, a fellow Professional Advisory Council member for American Citizens Abroad. ACA is a powerful non-partisan, non-profit volunteer association based in Geneva and...
In a little noticed IRS revision to one of its form letters just last August,[1] the IRS has signaled that it will be issuing more 90-Day Letters[2] in certain cases where a taxpayer fails to satisfy a revenue agent’s request for additional facts in an examination....
My last blog of November 3rd generated some lively emails and comments on LinkedIn and it appears as though I hit a nerve. There are plenty of IRS veterans still in place as well as alumni around who remember what the IRS field offices were like both before and after...
One of the best pieces of writing recently about the IRS’s continued downward slide, is Professor Emeritus Frank Wolpe’s white paper[1], which was published by the Taxation Section of the American Bar Association in its NewsQuarterly, 2014 Winter Issue, as its...
We are pleased to republish with permission from Roy Berg, on behalf of Moodys Gartner Tax Law, an excellent blog, which pertains particularly to “Canadian snowbirds.” As the article points out, the new Streamlined Procedures present an anomaly for “snowbirds” under...
Here is an interesting article by Andrew Velarde, published with permission from Tax Analysts, on Voluntary Disclosures which I thought you might find interesting. Practitioners Debate Fairness Of Lack of OVDP Retroactivity By Andrew Velarde — [email protected] The...
Mopsick Tax Law is pleased to announce that Kathleen Donelan-Maher is joining Ryan Carrere and Steve Mopsick as a law partner. Before joining MTL, Kathleen enjoyed a long and multi-faceted career in the accounting and tax fields. Kathleen started her academic career...
The June 18th IRS announcements have added some new words and dates to the debate, but for the practitioner, the analysis of the issues with regard to offshore compliance is still the same. Even as some of the decision points have shifted in representing clients...
Americans abroad should be pleased that IRS Commissioner John Koskinen kept his word when he advised us on June 3, 2014, to “stay tuned” in anticipation of new OVDP guidelines. The new guidelines make a distinction between those taxpayers who have been acting...
The Commissioner of Internal Revenue, John Koskinen , put the international tax bar in suspense when he announced in a major speech on June 3, 2014, that very shortly, the IRS is considering publishing something which is supposed make it possible for millions of...
