IRS

Eli S. Noff, Esq. CPA, Partner As we detailed in Section 199A: New 20% Pass-Through Deduction1, the Tax Cuts and Jobs Act of 2017 created new Internal Revenue Code §199A-providing a significant tax break to flow-through entities and structures. Subject to certain limitations, many eligible taxpayers (excluding C corporations) may deduct up to 20% of […]

Eli S. Noff, Esq. CPA, Partner On January 28, 2018, the court in U.S. v. Meyer,1considered a challenge to the proper mailing of Notices of Deficiency for two tax years and found Form 4340 sufficient as corroborating evidence for both years. Background A deficiency assessment results from the Internal Revenue Service’s (IRS) finding that a […]

The Treasury Inspector General for Tax Administration (“TIGTA”) completed an audit of the Offshore Voluntary Disclosure Program (“OVDP”). US citizens are taxed on their worldwide income and must report bank accounts when their aggregate balance exceeds $10,000. The OVDP and other similar programs allow taxpayers a mechanism to come forward and get into compliance with […]

The chief executive of Credit Suisse recently appeared in front of a Senate subcommittee to answer questions related to the bank’s role in aiding tax evasion. A similar hearing in 2008 resulted in a $780 million fine for Swiss bank UBS after the bank admitted helping U.S. taxpayers shield assets to avoid taxes. In conjunction […]

Eli S. Noff, Esq.,CPA, PartnerBrent Conrad In an effort to reduce persistent high unemployment rates resulting from the 2008 financial crisis, President Obama signed The Hiring Incentives to Restore Employment Act of 2010 (HIRE Act)1to incentivize employers to hire and retain workers. Tax incentives provided in the HIRE Act included: (1) a payroll tax holiday, […]

Eli S. Noff, Esq., CPA, Partner Under Internal Revenue Code (IRC) §6013(d)(3), spouses who file joint income tax returns are subject to joint and several liability for the income tax reported on those returns. In other words, the IRS will hold each spouse responsible for the entire amount of tax due. Sometimes, however, one spouse […]

Eli Noff, Esq., Partner On April 3, 2018, inUnited States v. Garrity, the U.S. District Court for the District of Connecticut considered the Government’s suit to reduce to judgment a willful Report of Foreign Bank and Financial Accounts (FBAR) penalty and determined that: (1) the burden of proof is preponderance of evidence, and (2) proof […]

Eli Noff, Partner On June 21, 2018, the Supreme Court delivered its highly anticipated decision in South Dakota v. Wayfair, Inc., et al.[1]The 5-4 decision discards the antiquated “physical presence rule” — a rule which has allowed retailers lacking a physical presence in a state to avoid any obligation to collect and remit sales taxes. […]

The Internal Revenue Service recently announced a major expansion of its Offer in Compromise program, which is aimed at helping individuals with past-due to taxes to pay off their debts to the IRS. Taxpayers who participate in the program are permitted to settle their tax debts for less than they owe if they are unable […]

Eli S. Noff, Esq., CPA, Partner The objective of the recently expired Offshore Voluntary Disclosure Program (OVDP) enabled willful U.S. taxpayers with undisclosed foreign assets to become compliant with U.S. tax laws, while concurrently avoiding serious statutory civil penalties and practically removing any risk of criminal prosecution. On November 29, 2018, the Internal Revenue Service […]