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Failure to File Information Returns For Foreign Trust Keeps Statute Of Limitations Open For Individual’s Income Tax

TweetShareSharePin0 Shares Fairbank v Commissioner  is the latest in a long line of important cases originating from the IRS’s use of the John Doe Summons (JDS) process to gather information about US individuals who had money parked in overseas accounts. Fairbank involves Section 6501(c)(8). That section provides that an individual who fails to file information

The IRS’s Aggressive Enforcement of Foreign Information Return Penalties Has Created Ethical Dilemmas For Practitioners (Part 2)

TweetShareSharePin0 Shares 0 Flares Filament.io Made with Flare More Info“> 0 Flares × In today’s post, Megan L. Brackney.turns to the challenging issues that practitioners must confront when faced with a client or potential client’s failure to file foreign information returns. Les Ethical Standards Related to a

The IRS’s Aggressive Enforcement Of Foreign Information Return Penalties Has Created Ethical Dilemmas For Practitioners (Part 1)

TweetShareSharePin0 Shares Today’s guest post is the first of a two-part series by Megan L. Brackney. These posts raise important questions about practitioners’ ethical responsibilities when confronting clients’ potential exposure to penalties for failing to file foreign information returns. Megan previously wrote a terrific series of posts considering problems with the IRS’s administration of these

The Facebook Pixel and Unauthorized Use and Disclosure of Tax Return and Tax Return Information

TweetShareSharePin0 Shares The Facebook Pixel and Unauthorized Use and Disclosure of Tax Return and Tax Return Information Last week The Markup, an online investigative journalism site, published a report about the presence of a Facebook (or Meta) pixel on various tax software websites that discloses taxpayer identity and financial information, gathered in the course of

Tax Court To Consider IRS Procedure For Imposing Information Reporting Penalties

TweetShareSharePin0 Shares In Information Return Penalty Assessment Fight Coming to a Head [$] Andrew Velarde highlights a major tax procedure issue before the Tax Court. It concerns allegedly improper IRS procedures with respect to the assessment of penalties associated with the delinquent or erroneous filing of information returns. As Velarde notes, in Farhy v Commissioner, the

Information from Administrative Practice Programming at the May ABA Tax Section Meeting

TweetShareSharePin0 Shares At each ABA Tax Section meeting certain committees have programing that directly impacts tax procedure, and we try to cover those committees.  At the May meeting none of the regular bloggers attended the Administrative Practice Committee meeting – usually one of the critical committee meetings for tax procedure information – but Abbey Garber

Guide released for tax pros’ information security plan

TweetShareSharePin0 Shares Tax and accounting professionals have a new resource for implementing or improving their written information security plan, which is required under federal law. The IRS in a news release Tuesday released a 29-page guide, Creating a Written Information Security Plan for Your Tax and Accounting Practice, which describes the requirements. The guide also

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