Tax Blog

Related Practice Areas: Tax Controversy And Litigation

• IRS Expands Innocent Spouse Relief to Protect Abused Spouses
  Posted January 17, 2012
  

  Author: Craig R. Cockrell

  In Notice 2012-8, the IRS has provided a proposed Revenue Procedure that would revise the factors used in evaluating requests for equitable innocent spouse relief under § 6015(f) and § 66(c) of the Internal Revenue …

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• No More Tax Strategy Patents
  Posted October 14, 2011
  

  Author: Anton Janik

  The Leahy-Smith America Invents Act (P.L. 112-29 9/16/2011), recently signed into law by President Obama, makes significant changes to the patent system and bars the patenting of tax strategies.  This bar applies only to new tax …

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• Fifth Circuit finds reasonable cause good faith exception from liability from accuracy-related penalties for LLC that relied upon law and accounting firm tax opinions supporting tax shelter
  Posted October 14, 2011
  

  Author: Anton Janik

  In Southgate Master Fund LLC v. United States, the Fifth Circuit Court of Appeals upheld the determination of the Federal District Court for the Northern District of Texas, which held that Southgate was not liable for …

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• IRS Releases Figures From Recent Offshore Voluntary Disclosure Initiatives; 30,000 Taxpayers Came Forward Paying Over $2.7 Billion in Tax, Penalties and Interest So Far
  Posted October 3, 2011
  

  Author: Anton Janik

  Early figures for the 2009 Offshore Voluntary Disclosure Initiative have been on the streets for some time now, but today the IRS released final figures for the 2009 OVDI program as well as preliminary figures for …

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• IRS Announces Voluntary Classification Settlement Program – Provides Tax Relief to Employers Who Reclassify their Workers from Independent Contractors to Employees
  Posted September 30, 2011
  

  Author: Anton Janik

  The new program will allow employers the opportunity to become complaint by making a minimal payment covering past payroll tax obligations, rather than waiting for an IRS audit to uncover past noncompliance. Under the program, set forth …

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• IRS Issues Final Guidance Holding That Employer-Provided Cell Phones are Generally Nontaxable as a Working Condition Fringe Benefit
  Posted September 30, 2011
  

  Author: Anton Janik

  Pursuant to IRS Notice 2001-72, where an employer provides employees with cell phones primarily for noncompensatory business reasons, neither the business nor personal use of the cell phone results in income to the employee, and no recordkeeping …

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