Inversion is by no means a new strategy for big businesses in avoiding high corporate taxes. However, the country to which companies are now moving is the dark horse known as the United Kingdom. For decades, Ireland was the destination of choice for inversion plans for U.S. companies, but after […]
Author: Lawrence Brown
The Internal Revenue Service recently issued a generally positive private letter ruling regarding Windstream’s plan to spin part of its company into a real estate investment trust. In an unusual move, the company will move its fiber optics and copper networks along with real estate into the REIT and then […]
Internal Revenue Commissioner John Koskinen said at a congressional hearing Wednesday that the IRS Inspector General has begun the process of reviewing agency computer backup tapes in an attempt to determine whether or not the missing emails can be recovered. The agency told law-makers in mid-June that a hard drive […]
White House officials said U.S. President Barack Obama will call for an end to a corporate loophole that gives companies a way to avoid taxes by reincorporating overseas, a practice known as inversion. The president plans to make these comments during a three-day fundraising swing for Democrats in Los Angeles […]
Senate investigators claim in a report released Monday that hedge funds used a tax avoidance technique known as basket options to dodge federal leverage trading limits, saving one well-known trading firm around $6.8 billion in U.S. taxes. The Internal Revenue Service, which warned in a 2010 memo against claiming a […]
A few weeks ago, we covered the 15-year prison sentence handed down in a tax fraud case against Paul Daugerdas for his role in designing and promoting sophisticated tax shelters. This week, a U.S. District Judge sentenced a cooperating witness in the criminal tax case to prison for six months. […]
The Obama administration voiced its opinion in a letter to leaders of the congressional tax-writing committees over urging lawmakers to pass legislation that would limit U.S. companies’ ability to reincorporate overseas for tax purposes. In the letter, Treasury Secretary Jacob Lew encouraged that lawmakers “should enact legislation immediately…to shut down […]
On July 17, 2014, the House passed legislation called the “America Gives More Act of 2014” (H.R. 4719). The bill contained “tax extenders” for two charitable tax breaks that could expire, but are normally renewed for one or two years at a time. In addition, there were two new ideas. […]
Internal Revenue Service Commissioner John Koskinen unveiled the agency’s plan to create a voluntary tax preparer certification program. The lower court and the appellate court in Loving V. Commissioner ruled that the IRS did not have the authority to regulate preparers. However, the IRS remained undeterred in its quest to […]
Following last month’s Zwerner decision, in which a Florida jury upheld three 50% civil FBAR penalties against a business man and banker, the IRS has again imposed the maximum civil FBAR penalty against a taxpayer for three years. Ashvin Desai, a medical device manufacturer living in San Jose, California, was […]