Staff Reductions & Insufficient Funding Will Dramatically Impact IRS in 2015 And Beyond
Last Tuesday, IRS Commissioner John Koskinen addressed the New York State bar Association Tax Section in New York. His comments provide keen insight into the going-on’s at the IRS. Mr. Koskinen’s most important announcement centered on the agency’s anticipated reduction in the number of rulemaking projects as a result of budgetary constraints. Although releasing guidance […]
Bulgaria Becomes Latest Country To Sign On To FATCA
Bulgaria is the most recent country to ink a deal with the United States to implement FATCA, the Foreign Account Tax Compliance Act. Passed by Congress in 2010, the law is designed to stomp out offshore tax evasion, by targeting U.S. taxpayers with unreported offshore accounts. Under the law, foreign banks and financial institutions must […]
Switzerland’s Bank Secrecy To Come Tumbling Down Like Berlin Wall When Automatic Exchange of Information Treaty Goes Into Effect
Author Samuel Jaberg sat down to interview Jacques de Watteville, Switzerland’s State Secretary for International Financial Matters. Mr. de Watteville is the man in charge of implementing Switzerland’s new treaty on automatic exchange of information between tax authorities. Before we dive into the interview, some background information about how the automatic exchange of information works is useful. According to […]
Is The U.S. Government On The Brink Of Launching A Tax Investigation Into HSBC?
The threat of U.S. prosecution looms over HSBC Holdings PLC like the sword of Damocles after a groundbreaking report revealed that it helped clients hide cash from various tax authorities. These reports cast HSBC, HSBC’s Holding’s parent bank, in an unsavory light and is the latest round of negative publicity to besmirch the British bank’s […]
HSBC Back In The Dog House Again
Last weekend, media reports cast an unflattering light on HSBC’s continued defiance to “straighten up and fly right” when it comes to assisting its foreign clients hide their accounts from taxing authorities in their home countries. The list of clients includes some you would least expect: global politicians, rock stars, arms dealers, and potential terrorists. […]
The Truth About ‘Luck’
This appeared in a blog post authored by Jason Zook. It is very profound. I couldn’t wait to share it with you. Why I don’t believe in luck For as long as I can remember, the saying, “you just got lucky” or “that person is so lucky” has always made me cringe. I’ve never believed […]
The Greatness Of Mickey Mantle And Louis Kovel
The 1961 Yankees occupy a special place in team history because, in my humble opinion, they were the only truly transcendent Yankee team between Joe DiMaggio and Derek Jeter. Mickey Mantle could have been a hero in a Sophocles play. He could have easily broken every offensive record in the book, but a tragic flaw, […]
How Not To Respond To A Subpoena
The following is an article written by Gavin Broady for “Law 360” on February 6, 2015. It is a great article that provides keen insight into how not to respond to a subpoena from those who are most likely to take exception to a show of such defiance: none other than DOJ Chiefs themselves. The advice in this article is invaluable. “Law360, […]
Getting to Know The Structure of The IRS
The IRS is an agency of the Treasury Department and is charged with the administration of the tax laws. It is the largest government agency in the world. Headed by the Commissioner of Internal Revenue, its structure is as follows: (1) There are four civil compliance divisions responsible for serving specific groups of taxpayers with […]
SB/SE Issues Memo Outlining Changes to the Limitations Period for Cases Going to and Coming from IRS Appeals
This article was co-authored by Randall Brody, EA of Tax Samaritan. I wish to acknowledge his keen insight and invaluable contributions to this article. Picture this. You receive a notice of determination from the IRS informing you that you owe more tax than you reported on your tax return. As is usually the case, the IRS […]