If federal authorities accuse you of tax fraud, the steps you and your attorney take in response are crucial. Given the complexity of the tax code, it is important to get counsel from an experienced tax attorney who knows how to defend and resolve criminal tax charges. In this post, […]
In the first part of this post, we outlined the basic considerations involved in defining when an organization is “closely held” for tax purposes. In this part of the post, we will look in more detail at how the Tax Court and the IRS have differed recently in interpreting and […]
By Brown, PC of Brown, PC posted in Offshore Accounts/International Tax Disputes on Thursday, March 26, 2015. Last summer, the IRS announced sweeping changes to its ongoing offshore compliance initiatives. The biggest change was the announcement of new Streamlined Compliance Procedures. Under these procedures, eligible taxpayers who resided in the […]
The Treasury Department announced a Final Rule this week to avoid having to reveal to PTIN holders the names of agencies that have requested their files. The purpose of the rule is to prevent these individuals from finding out that they are under investigation and destroying evidence. This new rules […]
Closely held businesses can sometimes seem synonymous with their owners. But for tax purposes, there are important respects in which that is not true. In this post, then, we will ask and address the following question: How does the IRS define a closely held corporation? The question is timely because […]
The IRS filed a federal tax lien against Robert De Niro, stemming from $6.4 million in unpaid tax liabilities from the 2013 tax year. The lien was filed on February 3, 2015, and the actor paid the balance in full three weeks later. The 71 year old actor, best known […]
Prior to his death in 1980, Maurice Pinot opened a Swiss account with approximately $1 million, which would pay interest and dividends to his longtime companion, and after her death, to her daughter. That daughter, Micheline Fournie, an 81 year old French citizen with U.S. residency, is now resisting pressure […]
There doesn’t seem to be a great deal of dispute among the politicos in Washington about whether the U.S. tax code needs reform or not. Just about everyone agrees it needs fixing. The question then becomes, just what is likely to be possible considering the current makeup of Congress and […]
A former UBS client has been sentenced to four months of incarceration and two years of supervised released by a federal court in Georgia. The internet entrepreneur was convicted of FBAR violations, stemming from his undeclared offshore accounts in Switzerland and other countries. Gregg Kaminsky, the founder and CEO of […]
The owner of Le Perigord, a popular French restaurant in Midtown Manhattan, has pleaded guilty to obstruction charges stemming from undeclared Swiss bank accounts he held from 1992 to 2011. Georges Briguet, 77, grew up on his family’s vineyard in Switzerland. In 1960, he moved to New York and opened […]