The Trouble With Tax Relief Firms

We are bombarded with advertisements from JK Harris, TaxMasters, Roni Deutch, and a host of other tax relief firms, asking that we let them help with IRS audit and collection problems.  Many give examples of tax debts being settled for pennies on the dollar.  They imply that your case will be handled by former IRS […]

Voluntary Disclosures

The IRS has long had a voluntary disclosure policy which enables taxpayers who want to clean up problems that expose them to criminal prosecution to make a voluntary disclosure through the Criminal Investigation Division and to negotiate an agreement under which their problems can be settled without criminal prosecution. In recent years that policy has […]

Trouble In The Legal Industry

August 7th, 2013 I recently saw an interview of Steve Harper, a former Kirkland & Ellis lawyer (a big international law firm) who recently published a book titled The Lawyer Bubble:  A Profession in Crisis.  Points made in this book are: There are only jobs in the industry for approximately one-half of the lawyers who […]

U.S. Offshore Account Enforcement Issues

August 7th, 2013 This is a digest of presentation made to the 2013 NYU Tax Controversy Institute by Scott Michael of Kaplan & Drysdale in Washington. Since 2008, IRS has been aggressively moving against thousands of taxpayers who maintain foreign bank accounts that do not get reported on their tax returns.  There is a growing […]

IRS Criminal Investigation

Criminal investigations at IRS are handled by the Criminal Investigation Division (CI) that operates through approximately 2,600 special agents.  Cases investigated by CI are reviewed by attorneys with the IRS Chief Counsel Office and then forwarded to the Department of Justice for further review and prosecution.  CI is the gateway for the IRS offshore voluntary […]

Immigration Tax Problems

Before 2013 is over we will probably have comprehensive immigration reform. The political talk is that to become a citizen it will be necessary to file un-filed tax returns and pay any taxes owed. Until we see the final legislation we won’t know what sort of compliance will be required, but I would anticipate 3 […]

Reporting Foreign Income and Interests in Foreign Entities

June 19th, 2013 An article by Richard Satran in the 05/10/2013 US News, reports “The Internal Revenue Service relies on technology more than ever to sniff out tax cheats using robo-audits and data mining – but so far it has caught a lot of minnows and the big fish are still eluding detection.” Without much […]

Swiss Banks Cave on Bank Secrecy

A 05/28/2013 article in the New York Times reports that: The Swiss government said on Wednesday that it would allow its banks to disclose information on American clients with hidden accounts, a watershed move intended to help resolve a long-running dispute with the United States over tax evasion. The decision, which comes amid widening scrutiny […]

Problems at the IRS

In its May 25, 2013 edition, The Economist has an article about the IRS scandal, which is entitled “Who Will Tame the Taxman?” The part that interested me was not the discussion of alleged targeting of conservative organizations by the exempt organizations group, but its summary of other problems the IRS lives with. I quote […]

Sales Tax Comes Back to Bite Online Buyers

June 14th, 2013 Online shopping is the latest and greatest way to shop. It may seem simple if you’re surfing Ebay or Craigslist, and harmless if you make a purchase or two. Online shopping is fun and easy, and having the ability to order from different parts of the country gives you even more variety. […]