By Megan L. Brackney Tax Notes In this article, Brackney discusses the John Doe summons procedures and the decision partially enforcing a John Doe summons in Coinbase. She also identifies some practical considerations for taxpayers whose information may be turned over to the IRS in accordance with
By Juliet L. Fink The CPA Journal March 2020 Edition Section 7623 of the Internal Revenue Code (IRC) allows for the payment of financial awards to those who blow the whistle on individuals or corporations that have deliberately underreported or underpaid their taxes. Such awards are
By Sharon L. McCarthy The CPA Journal March 2020 Edition Brian Nelson Booker has the dubious distinction of being the first person criminally charged by the Department of Justice (DOJ) with allegedly making false statements in connection with the IRS’s Streamlined Domestic Offshore Program (SDOP). The
By Sidney Kess and Julie Welch The CPA Journal February 2020 With stocks at or near record levels, prudent financial planning might call for taking defensive measures. One strategy could be to focus on dividend-paying stocks. Companies that make enough money to distribute some to shareholders
By Usman Mohammad The CPA Journal February 2020 Edition Foreign asset reporting—including the reporting of foreign retirement plans—is a high priority for the IRS, which in 2019 listed the “failure to report offshore funds” as one of its “Dirty Dozen Tax Scams,” and has done so
By Sidney Kess The CPA Journal January 2020 To fund the government through the end of its 2020 fiscal year and provide funding for various projects and purposes, Congress passed a massive spending measure just before adjourning for the Christmas holiday; this measure was signed into
By Michael Sardar The CPA Journal January 2020 Edition Cryptocurrency is here to stay. As of November 17, 2019, the top five cryptocurrencies by market capitalization had a combined value of approximately $196 billion, and consumers can now use cryptocurrency in place of legal tender at
By Megan L. Brackney Procedurally Taxing January 8, 2020 The Gifts That Keep on Giving Two young people moved to the U.S. as students. They met in graduate school and married. After graduation, they were offered jobs and were sponsored by their employers so that they
By Megan L. Brackney Procedurally Taxing January 7, 2020 Reasonable Cause For all of the foreign information return penalties, reasonable cause is a defense. See I.R.C. §§ 6038, 6038A(d)(3), 6038D(g), 6039F(c)(2), 6677(d); Treas. Reg. § 1.6038-2(k)(3)(ii). The IRS applies the same standards for reasonable cause for failure to file income tax returns under I.R.C. §
By Megan L. Brackney Procedurally Taxing January 6, 2020 The IRS has been assessing more and more foreign information return penalties on taxpayers. It is difficult to find statistics on this point, as the IRS’s reports on tax penalties lump all “nonreturn” penalties into one category, which
