tax Archive

TweetShareSharePin0 Shares In its jurisprudence since 2006, the Supreme Court has firmly stated that claim-processing rules (of which filing deadlines, it says, are the quintessential claim-processing rule) are not jurisdictional.  However, the Court has articulated two exceptions:  One is if Congress makes a “clear statement” in a statute that it wants the claim-processing rule to

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

TweetShareSharePin0 Shares The Tax Policy Center has revised its estimates of the revenue cost and distributional effects of the business tax cuts included in its analysis of several tax changes currently pending in the post-election session of Congress. TPC analyzed the effects of eliminating a scheduled phase-down in 100 percent bonus depreciation. However, TPC incorrectly

TweetShareSharePin0 Shares In this post, I will discuss the legislative history undergirding the argument over which provision provides the Tax Court’s deficiency jurisdiction and point out things that the Hallmark opinion oddly decided not to discuss about this legislative history, even though the taxpayer presented this information to the court. The Hallmark opinion (slip opinion

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

TweetShareSharePin0 Shares Denied a seat at the table to decide tax rules, African countries moved the table to the UN. Malawi loses US$58 million in tax per year due to cross-border tax abuse by multinational companies. And this is just the tip of the iceberg as it’s hard to count illicit money because it’s hidden.

TweetShareSharePin0 Shares Today’s guest blogger is Joseph Cole, LL.M.  He is an Associate Attorney at RJS Law in San Diego, California.  His practice includes federal and state tax controversy. Today’s post discusses a recent California case applying the Boyle doctrine to an electronically filed return.  Like many cases applying the Boyle doctrine, the California case