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Reps. Waxman and Stupak: Beware IRC Sec. 6103?
By Jonathan Prokup President Obama’s health-care legislation is becoming more of a tax issue on a daily basis. In addition to the codification of economic substance (discussed here; see also...
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Mind the Gap: TRAC Audits the Auditors
By Jonathan Prokup The New York Times and Forbes Magazine are reporting on a study by the Transactional Records Access Clearinghouse, a research group affiliated with Syracuse University, which claims...
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Fox Business Interview: OVDI, FBARs, And The Economic Benefits Of A...
By Jonathan Prokup Fox Business invited me to appear yesterday on “After The Bell” with Liz Claman and David Asman to discuss (i) the IRS reopening the disclosure initiative for offshore bank accounts...
View ArticleReps. Waxman and Stupak: Beware IRC Sec. 6103?
President Obama's health-care legislation is becoming more of a tax issue on a daily basis. In addition to the codification of economic substance (discussed here; see also yesterday's TNT story...
View ArticleMind the Gap: TRAC Audits the Auditors
The New York Times and Forbes Magazine are reporting on a study by the Transactional Records Access Clearinghouse, a research group affiliated with Syracuse University, which claims to show that the...
View ArticleFox Business Interview: OVDI, FBARs, And The Economic Benefits Of A...
Fox Business invited me to appear yesterday on “After The Bell” with Liz Claman and David Asman to discuss (i) the IRS reopening the disclosure initiative for offshore bank accounts and (ii) the...
View ArticleBiden Administration Proposes to Curtail Section 1031 “Like-Kind” Exchanges
Section 1031 “like-kind” exchanges have long been a useful tool for family and closely held business planning. For example, business enterprises have been able to exchange commercial or industrial...
View ArticleTax Court Protects Collection Due Process Rights
When the IRS reaches (in the words of Tax Court Judge Mark Holmes) the “we're taking your stuff” stage to collect back-taxes, taxpayers generally have the right to a collection due process (CDP)...
View ArticleFinal Partnership Audit Regulations Are Deja Vu All Over Again
For decades, tax audit procedures for partnerships had been governed by a framework established in the Tax Equity and Fiscal Responsibility Act of 1982. This partnership audit regime was commonly...
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