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
We are pleased to announce the promotion of Jacqueline A. Schneegold to Senior Paralegal. Mrs. Schneegold has been with the firm since July 2004. She assists in the practice areas of audit representation, tax litigation, criminal tax and FATCA & Foreign Bank Account Reporting Issues. Mrs. Schneegold is also the firm’s Marketing Director.
By: Randall P. Andreozzi Recent revisions to the IRS Offshore Voluntary Disclosure Programs illustrate that the Service is becoming more aggressive and less tolerant with those taxpayers who have not yet come forward to report their interests in foreign bank accounts. The IRS on June 18, 2014, published new Streamlined Filing Compliance Procedures. The new Programs – one for U.S.
By: Gary Bluestein, Esq. Federal tax law can impact virtually every area of legal practice. For example, in debtor/credit law, certain property is protected from enforced collection, such as a 401K, IRA or homestead exemption. There is additionally a 10% limitation on wage garnishment. However, none of these exemptions apply to the Internal Revenue Service. Bankruptcy Law also treats tax creditors
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
We are pleased to announce the promotion of attorney Tiffany D. Bell from Associate Attorney to Senior Associate. Mrs. Bell is a graduate of the University at Buffalo Law School. She is admitted to practice in New York State. She focuses her practice on tax controversy and international tax compliance.
We are pleased to announce the promotion of attorney Michael J. Tedesco from Associate Attorney to Senior Associate. Mr. Tedesco is admitted to practice in New York State, the United States Virgin Islands, and before the U.S. Tax Court. He focuses his practice on tax controversy and international tax compliance.
Generally speaking, most taxpayers, including individuals and trusts, are denied the use of their passive activity losses and credits to offset ordinary income under the passive activity loss (“PAL”) rules of Section 469 of the Internal Revenue Code (the “I.R.C.”). These PAL rules prevent investors from utilizing losses incurred in income-generating activities in which they are not materially involved, thus
With the upcoming hype surrounding taxes as April 15th approaches, anxiety increases for those in tax trouble. A significant number of people have been contacted by the taxing authorities about missing tax returns, or are nervously anticipating such contact. Others already have an assessed liability and are facing enforced collection action. What many individuals who have not filed do not realize
On February 20, 2014, the United States Court of Appeals for the Eleventh Circuit released an opinion allowing the Government of the United States Virgin Islands (“USVI”) to intervene in three cases consolidated for appeal. The Eleventh Circuit reversed the U.S. Tax Court’s denial of the USVI’s motions to intervene in the three cases. In each case, the taxpayers, each of