Library Search
-
Beyond the Legend: The Impact of New Circular 230 ( October 2005 )
By now, corporate taxpayers will have noticed a change in much of the written tax advice they have received from their outside tax advisers after June 20, 2005. This change is the immediate result of new regulations the U.S. Treasury has issued to regulate advisers who provide U.S. federal tax advice. The Treasury issued these regulations (which are referred to as "Circular 230") under its statutory authority to regulate those who are authorized to practice before the Treasury and the Internal Revenue Service. -
Tax Litigation Primer ( June 2004 )
Tax litigation is not for the faint of heart. Almost no one wins everything requested, and certainly not every time. Nonetheless, the taxpayers with whom I deal invariably tell me that in the long run taking an aggressive posture saves their companies tax dollars that they should not have to pay. -
Trustees May Be a Target of IRS Audits ( May 2004 )
A recent article in <i>The Bond Buyer</i> reported that the IRS will begin an audit program sweep this summer to examine whether the failure by trustees to roll escrow funds held under refunding escrows for tax-exempt issues into zero-interest rate State and Local Government Series (SLGS) securities may have resulted in issuer arbitrage violations. -
IRS Revises Scope of Tax Shelter Regulations LimitingCoverage of Confidential Transactions ( January 2004 )
On December 29, 2003, the Treasury Department and the IRS issued revised regulations that dramatically limit the circumstances under which a confidential transaction must be disclosed under the tax shelter rules. In addition, the IRS issued new rules intended to increase transparency and disclosure of information by taxpayers to deter abusive tax avoidance transactions. -
Christmas in May: Tax Court Judge Lynn W. Davis' Extraordinary Decision ( October 2003 )
Usually with indignant disbelief, my taxpayer clients often lecture me that constitutional safeguards routinely extended to others, like accused felons and “garden variety” plaintiffs, find no counterparts in the tax world. The taxpayers’ point is that the state must prove criminal guilt “beyond a reasonable doubt,” while the reverse applies to taxpayers, who must prove the taxing authorities’ presumptively correct assessments are wrong. -
Corporate Tax Shelters--What Will Be the Impact of the New Regulations on U.S. Multinational Corporations? ( October 2001 )
Introduction In late February of this year, the Internal Revenue Service issued three sets of temporary and propo. -
Change in Ohio Taxation of Electing Small Business Trusts ( January 2000 )
This article details some recent business tax changes in Ohio. -
IRS Announces 2001 Cost of Living Adjustments for Benefit Plans ( December 2000 )
This article addresses the 2001 cost of living adjustments for benefit plans.
Ads by FindLaw