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Former IRS Tax Attorney
A Leader in Offshore Disclosures - Tax Litigation - Tax Resolution

news & insights

Independent Contractor vs. Employee: Factors to Consider – Categorizing workers as contractors or employees has major tax effects. If this important tax planning detail is overlooked, a business or a business person can be left with the tax bill of its workers. Moreover, the difference in designations can result in significant compliance and overhead costs. The success of a business can depend on this designation; it is often worth the time and money to explore how to do things correctly.

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Recently the IRS has used I.R.C. § 280E to disallow claimed deductions taken by taxpayers in relation to medical marijuana dispensaries. A recent court case has strengthened the IRS’s position in this regard. I.R.C. § 280E says no deduction or credit shall be allowed for any amount paid or incurred during the taxable year in […]

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Recently The Fourth Circuit Court of Appeals made a controversial decision regarding willfulness as it applies to FBAR obligations. United States v. Williams, No. 10-2230 (4th Cir. July 20, 2012). This ruling may add risk to opting out of the Offshore Voluntary Disclosure Program or disclosing foreign bank accounts late without entering into the Offshore […]

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Grammy Award winning R&B star, R Kelly, 44, is another name just added to the roster of celebrities who have failed to pay their income taxes, joining the likes of Dennis Rodman and most recently Lauryn Hill. Kelly reportedly owes more than $4.8 million in taxes dating back to 2005. According to MTV, the breakdown […]

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Accounting Firm Admits Criminal Wrongdoing in Connection with Fraudulent Tax Shelter Scheme that Generated at Least $6.5 Billion in Phony Tax Losses Preet Bharara, the United States Attorney for the Southern District of New York, Douglas H. Shulman, the Commissioner of the Internal Revenue Service (“IRS”), and John A. DiCicco, the Principal Deputy Assistant Attorney […]

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Big news from the Offer and Compromise (OIC) front. On May 21, the IRS announced more flexible terms to help a greater number of struggling taxpayers make a “Fresh Start” with their tax liabilities. This phase of Fresh Start will assist some taxpayers who have faced the most financial hardship in recent years, said IRS […]

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In a Tax Notes Today report of statements made at the Eastern Pennsylvania Working Together Conference in Malvern, PA, Jason Kuratnick, IRS Associate Area Counsel (Philadelphia), Small Business/Self-Employed Division is reported to have said. The IRS may send a warning letter in lieu of asserting penalties for failure to file a Form TD F 90-22.1, […]

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Switzerland’s oldest bank was indicted back on February 02, 2012 for conspiring with U.S. taxpayers and others to hide more than $1.2 billion in secret offshore foreign banks and financial accounts and the income they generated from the IRS. It was the first time in history that an overseas bank was indicted by the United […]

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The IRS continues to pursue undisclosed offshore bank accounts aggressively. Although the IRS started with taxpayers hiding money with UBS in Switzerland as outlined below, they have quickly moved to other Swiss banks. UBS (Union Bank of Switzerland) Clients Jan. 30, 2012 — Stephen M. Kerr, Michael Quiel and Christopher M. Rusch were charged in […]

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Yesterday, a federal grand jury in San Jose, California, indicted Ashvin Desai of San Jose on three counts of tax evasion on $1.3 million in unreported interest income, two counts of willfully aiding the preparation of materially false tax returns and three counts of failing to file Reports of Foreign Bank and Financial Accounts (FBARs), […]

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