IRS

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 […]

According to the February 21, 2018, IRS news release, IR-2018-32, there are still circumstances for which interest on home equity loans is still deductible under the Tax Cuts and Jobs Act of 2017. The IRS has now clarified that “taxpayers can often still deduct interest on a home equity loan, home equity line of credit […]

Leanne Broyles, Esq. Part I Everyone has their own personal reasons for charitable giving, whether it be sharing with those less fortunate, supporting an alma mater, or assisting a deserving cause or an organization that means something to them. Regardless of your charitable motives, before making a substantial gift or bequest to a charity, you […]

Glen E. Frost, Managing Partner When the Tax Cuts and Jobs Act reduced the C corporation tax rate from 35% to 21%, it also created a significant tax break for flow-through entities and structures in an attempt to level the playing field for small businesses.1As such, beginning January 1, 2018, S corporations, partnerships, limited liability […]

Glen E. Frost, Esq., CPA, Managing PartnerJohn Pontius Foreign Bank Account Reporting Extends Beyond Switzerland: FATCA Updates For the last six years, most of the focus of offshore tax evasion has been on Swiss bank accounts. However, the Internal Revenue Service will soon be broadening their investigations into other foreign countries with the implementation of […]

Glen E. Frost, Managing Partner The Tax Cuts and Jobs Act of 2017 (TCJA) introduced Qualified Opportunity Zones (QOZ),1created to stimulate economic and property development in low-income communities in order to reduce poverty and increase employment. The program is immensely attractive to investors, because those who invest in QOZs using Qualified Opportunity Funds (QOFs) and […]

In November of 2017, Coinbase, Inc. (“Coinbase”), a company that facilitates digital currency transactions, was ordered to comply with an IRS summons demanding specific Coinbase client identifying information and transaction data for Coinbase accounts “with at least the equivalent of $20,000 in any one transactions type” in any year during the period of 2013-2015.[1]Approximately 14,000 […]