Civil Tax Penalties: Don’t Party Like It’s 1999 Just Yet
Immediately after the lead juror announces a “not guilty” verdict in a criminal tax lawsuit, nearly everyone at the counsel table reacts like this. However, just like O.J. Simpson’s legal problems were far from over that day, a criminal tax trial is only round one. Before the ink is dry on the jury form, the […]
‘Close’ Only Counts In…Tax Accuracy Penalty Cases?!
After the California Angels dropped a tough 7-6 decision to the Kansas City Royals (normally reliable reliever Rudy May had a rare bad game, giving up two runs in the bottom of the eleventh inning), baseball great Frank Robinson sagely remarked that “Close don’t count in baseball. Close only counts in horseshoes and hand grenades.” […]
Liability for Trust Fund Taxes
As a rule, workers look forward to payday, even if their meager restitution isn’t as much as they would like it to be. Visions of sugarplums dance in their heads, or at least visions of one less bill emblazoned with the dreaded “Past Due, Please Remit” stamp. As a rule, employers dread payday. Even if […]
Getting To Know Form W-8BEN And What It’s Used For
Non-U.S. persons must pay U.S. tax on certain kinds of income they receive from U.S. sources. Typically, the income is taxed at a flat rate of 30%. The only exception to paying the full amount is if an income tax treaty exists between the U.S. and another country that authorizes a lower rate of tax. Let’s take a slight […]
The Civil Fraud Penalty
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Failure to File a Tax Return Penalty
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The Accuracy-related Penalty
Under Section 6662(a), the accuracy-related penalty is “20% of the underpayment.”[i] It applies both inside and outside of the OVDP regime. The penalty applies whenever any one of five conditions is present. The two most common are: (1) “negligent or intentional disregard of tax rules” and (2) “substantial understatement of income tax.”[ii] Has the statute […]
Anatomy of a Civil Tax Controversy: A Free Webinar
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How ‘Big Brother’ Gathers Information in the Digital Age: A Free Webinar
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Alphabet Soup for Partnerships
Attached is the outline.