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By: Michael J. Tedesco, Esq. Introduction to IRS Appeals IRS Appeals is a separate branch of the IRS, whose purpose is to resolve tax controversies between the IRS and taxpayers through an informal, administrative process, fairly and impartially, without litigation. IRS Appeals has substantive experts in many of the same areas as the IRS (i.e. designated personnel who deal only
By: Michael J. Tedesco, Esq. We find that accountants and taxpayers are often unfamiliar with certain aspects of the typical tax controversy (i.e. how a tax matter moves through assessment, Tax Court/Appeals and Collections). We have put together a series of articles moving through “The Lifecycle of a Tax Controversy”. What follows is the first part of what will be
By: Michael J. Tedesco, Esq. On December 22nd, 2017 with one stroke of a pen, president Trump signed into law the most sweeping tax law changes in a generation. For the first time in over 30 years tax professionals will confront significant changes in the tax law that will impact planning, reporting and enforcement matters. While the true impact of
By: Michael J. Tedesco As another filing season is upon us, it is important to be aware of the extensive information reporting associated with holding assets outside of the U.S. Failing to file necessary information returns or filing incomplete information returns can result in substantial penalties. FBARS – U.S. Persons, meaning individuals and entities, with a financial interest in or
Buffalo Law Journal’s Michael Petro interviewed Andreozzi Bluestein’s Senior Associate Michael Tedesco and Associate Heather Schmidt on federal and state compliance issues for his Tax Law Special Report. Petro’s federal article discusses recent trends in foreign bank reporting issues for both U.S. citizens and international banks. The IRS began allowing taxpayers to come forward with respect to their foreign accounts
By: Michael J. Tedesco A Federal Judge recently approved the Internal Revenue Service’s issuance of what is known as a “John Doe” summons¹ to several entities in the U.S who utilized the services of Sovereign Management & Legal Ltd. (“Sovereign”). These entities include FedEx, DHL, UPS, Western Union, the Federal Reserve Bank of New York, Clearing House Payments Company LLC
By: Michael J. Tedesco On June 18, 2014, the Internal Revenue Service (“IRS”) announced significant changes to the offshore voluntary disclosure programs. As part of the announcement, the IRS has expanded the 2012 Streamlined voluntary disclosure program to allow U.S. residents to participate in a version of that program. Additionally, the IRS has made several changes to the 2012 Offshore