The New Deduction for Pass-Through Income (or How Congress Failed at Tax Simplification)
One of the more significant changes in the recently enacted Tax Cuts and Jobs Act is new Internal Revenue Code Section 199A, Qualified Business Income. Although touted as providing tax simplification, the Tax Cuts and Jobs Act created a pretty complex new tax concept – the pass-through deduction. …
DOJ Announces Major New Shift in Criminal Sentencing in Offshore Tax Matters
December 8, 2017
by Anton L. Janik, Jr.
At the 34th Annual National Institute on Criminal Tax Fraud in Las Vegas yesterday afternoon, Mark Daly, DOJ Tax Division Senior Litigation Counsel announced a major new shift in how the Department of Justice plans to argue offshore tax prosecution defendants should be sentenced. Instead of…
The Case Against Do-It-Yourself Tax Returns: You Don't Know What You Don't Know
November 6, 2017
by Ashley L. Gill
In an effort to comply with the increasing complexity of the Internal Revenue Code (the “Code”) and the regulations promulgated thereunder, many taxpayers are looking to tax preparation software for assistance in preparing their own tax returns. According to the IRS’s filing season statistics for…
What Practitioners Need to Know about the New Partnership Audit Rules
November 6, 2017
by Craig R. Cockrell
As you’ve surely heard by now, the Bipartisan Budget Agreement of 2015 (“BBA”) enacted new IRS procedures for partnership audits for tax years beginning on or after January 1, 2018. The new audit rules allow the IRS to collect taxes directly from most partnerships rather than from their partners…
So, What's Up With Estate Tax Repeal …
Mid-Fall of last year I was working with a client on a sale of an interest in a closely-held business to a grantor trust. A detailed business valuation was in process when then candidate Trump became President-elect Trump. Suddenly candidate Trump’s campaign platform, which included the repeal of…