An IRS “John Doe” Summons is a Powerful Weapon that can Puncture Attorney-Client Privilege

November 2019

An individual that provides information to an attorney may normally assume that the information provided to the attorney will be kept confidential under the attorney-client privilege.  That said, according to the Internal Revenue Manual (IRM), circumstances exist when attorney client

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El Programa de Cumplimiento de Sanciones de la OFAC le aplica a todos

November 2019

OFAC (Oficina de Control de Activos Extranjeros) es un departamento del Tesoro de los Estados Unidos que administra y aplica sanciones económicas y comerciales basadas en la política exterior de los Estados Unidos y los objetivos de seguridad nacional. El

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The OFAC Sanctions Compliance Program applies to all

November 2018

OFAC (Office of Foreign Assets Control) is a department of the US Treasury that administers and enforces economic and trade sanctions based on US foreign policy and national security goals.    On May 2, 2019, OFAC published guidance titled “A

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Why is it important to choose the right Power of Attorney for your IRS representation?

October 2019

Circular 230 (Regulations Governing Practice before the Internal Revenue Service) governs those that are authorized to practice in front of the IRS:  Attorneys, CPAs and Enrolled Agents.  Practicing in front of the IRS means that those authorized may: Communicate with

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Did you know that the IRS has 59 Compliance Campaigns? Have your Audit Plan Ready!

October 2019

IRS Large Business and International (IRS LBI) currently has 59 Active Compliance Campaigns.  The purpose of the IRS compliance campaign strategy is to redefine large business compliance work and build a supportive infrastructure inside the LBI.  The campaigns require strategic

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Guilty from the Get-go in the IRS Updated Voluntary Disclosure Program?

September 2019

On June 20, 2019, the National Taxpayer Advocate (TA), an independent organization within the IRS that helps taxpayers and protects taxpayer rights, issued a final Report to Congress.  A section of the report focused on the TA’s request for the

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Could your Organization be holding Virtual Currency that is “blockable” pursuant to OFAC’s regulations?

September 2019

OFAC (Office of Foreign Asset Control) compliance applies to all US persons; including, all US citizens and permanent resident aliens regardless of their location, all persons and entities within the US, all US incorporated entities and their foreign branches, all

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IRS Initiates a Compliance Campaign for U.S. Persons with respect to Certain Foreign Corporations

September 2019

IRS Form 5471 is used by certain U.S. persons who are officers, directors, or shareholders in certain foreign corporations and must be attached to a covered Taxpayer’s Tax Return.  On April 16, 2019, IRS announced the approval of three additional

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Your Tax Home and Travel Expense Deductions

August 2019

The Internal Revenue Code (IRC) permits a U.S. Taxpayer to deduct  “certain travel expenses” when traveling away from home on business.   Taxpayers ought to keep close attention to a travel expense deduction and ensure that it accurately correlates with a

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When do you need an IRS Certifying Acceptance Agent?

August 2019

There are foreign national Individuals and other foreign Persons that do not have or do not qualify for a Social Security Number (SSN) but need a  https://www.jdsupra.com/legalnews/when-do-you-need-an-irs-certifying-16624/

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Does it make sense to go from an S-Corp to a C-Corp?

August 2019

IRS defines an S-Corp as a corporation whose shareholders make the election to pass corporate income, losses, deductions, and credits through to their shareholders for https://www.jdsupra.com/legalnews/does-it-make-sense-to-go-from-an-s-corp-45960/

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What is an Abusive Tax Trust?

August 2019

In a “legitimate” Trust, the ownership and control of the Trust assets and income is “separate” from a Settlor’s control and https://www.jdsupra.com/legalnews/what-is-an-abusive-tax-trust-56770/

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