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By: Randall P. Andreozzi, Esq. In 2016 the IRS issued Notice 2016-66, which identifies certain micro captive insurance transactions as potentially abusive. The Notice generally describes the abusive arrangement as one where owners of closely-held entities engage in a captive insurance arrangement that purports to ensure against certain risks associated with the business. The business pays “premiums” to the captive
By: Gary P. Bluestein Many accountants incorrectly assume that their communications with their tax clients are always privileged and confidential. Unfortunately, sometimes tax cases can cross over into potential criminal exposure for a client, and not knowing the scope and limitations of privilege can be devastating, both to the practitioner and to the client. Although there is limited privilege provided
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: John L. Marien On December 22, 2017, President Trump signed into law the Tax Cuts and Jobs Act. In light of the various tax cuts contained in the revisions to the Internal Revenue Code, Congress was compelled to formulate legislation that would recover some of the lost revenue. One provision aimed at recovering a portion of this revenue loss
By: Tiffany D. Bell, Esq. In 2010, Congress added to the anxiety of tax practitioners when it expanded the statute of limitations for the IRS to assess income taxes to six years when a taxpayer fails to include Form 8938 with his tax return. Taxpayers use Form 8938 to report to IRS foreign bank accounts and other specified foreign financial
By: Randall P. Andreozzi, Esq. The IRS announced on Wednesday that it will officially end the 2014 Offshore Voluntary Disclosure Program (affectionately known to practitioners as the “OVDP”) on September 28, 2018. The Agency urged taxpayers who still have not come forward to do so before the program ends. The 2014 OVDP is the last evolution of the program IRS
In a court-reviewed opinion published on January 29, 2018, the U.S. Tax Court in Coffey, et. al. v. Commissioner, 150 T.C. No. 4, found in favor of the taxpayers and dismissed the Internal Revenue Service’s Statutory Notices of Deficiency against them as time barred. Andreozzi Bluestein LLP represented the Petitioners in this case before the Tax Court. The Petitioners claimed
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: Justin J. Andreozzi, J.D.; Randall P. Andreozzi, J.D.; and Arlene Hibschweiler, MBA, J.D. While at one time, the IRS would discontinue a civil examination when it began a criminal investigation of a taxpayer, it is now the IRS’s policy in certain situations to conduct simultaneous civil and criminal investigations in what are called parallel investigations. While, technically, the civil
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