ARTICLES

The United States Department of Justice has announced that it has reached a plea agreement in a criminal charge against a bank director who voluntarily disclosed hidden offshore income without taking advantage of the IRS's Offshore Voluntary...

Absent congressional action, employers will face a tax dilemma beginning July 1, 2011. The "temporary" 0.2 percent federal unemployment tax (FUTA) surtax is scheduled to expire June 30, 2011. The surtax is part of the 6.2 percent gross unemployment...

Both government agencies and government contractors will need to prepare for the effects of new withholding rules. Tax law contains a provision that requires the federal government and every state and local government making payments for goods or...

A family limited partnership can be an effective estate planning tool. However, to be successful in removing future appreciation in value from the estate of a wealthy family member, it is important that the family limited partnership (FLP) meet...

A recent private letter ruling illustrates the dangers inherent in using IRA funds as a source of short-term financing. Normally, you can avoid tax on a distribution from a traditional IRA if you roll the money over to another IRA or other eligible...

If the soaring price of gasoline has not deterred you from purchasing a SUV, you may be able to take advantage of a perhaps unintentional tax break.   For a limited time only, the 100 percent bonus depreciation rules allow a complete write-off...

The IRS has issued a memorandum describing the penalty framework that will apply to those who voluntarily disclose assets hidden in offshore accounts. The new program is a followup to voluntary disclosure efforts conducted two years ago. Every U.S....

The Supreme Court has refused, without comment, to bypass the court of appeals and review a Virginia district court decision that challenges the constitutionality of the Patient Protection and Affordable Care Act.   In Virginia ex rel....

Several courts are addressing the legality of an IRS regulation, with mixed results.   Late last year, the IRS issued final regulations describing conditions under which it will be allowed six years – instead of the normal three years – to...

Congress has passed, and the President has signed, the Comprehensive 1099 Taxpayer Protection and Repayment of Exchange Subsidy Overpayments Act of 2011. This bill repeals the expansion of the Form 1099 reporting requirement contained in 2010...

A new revenue procedure creates a safe harbor for companies that have incurred "success fees." Success-based fees are amounts that are contingent on the successful closing of a transaction (most often, investment banker fees). They are presumed to...

In a case dealing with a charitable contribution for a façade easement, the Tax Court ruled that the gift did not result in a charitable contribution deduction because a bank held a mortgage on the underlying property. The easement involved a...