by Greg BryantNew IRS Offshore Account Program
OVDP offered taxpayers whose conduct was considered “willful” as to the nonreporting of foreign income with a path to compliance and more importantly an opportunity to diminish the threat of criminal charges they may face upon discovery by the IRS.
by Gary WellsThe Cybersecurity Threat, Burden, and Role of Tax Practitioners
Tax practitioners have learned that they possess something that a new breed of criminals, namely cybercriminals, desire—information.by Gary WellsStay Off IRS List and Secure Relief for Prior Nonreporting of Foreign Accounts and Other Assets
NOT TOO LATE to Stay Off IRS List and Secure Relief for Prior Nonreporting of Foreign Accounts and Other Assets (FBAR and others)by Gary WellsYearend Also Brings End to Startups Opportunity to Elect to Monetize R&E Income Tax Credit as Payroll Tax Credit for 2016
IRS and Department of Treasury provided operational rules for 2016 that allow at least for the 2016 tax year an extension of time for taxpayers to make the election on or before December 31, 2017 to treat R&E tax credits as a Payroll Tax Credit and claim the benefit against the next payroll tax filing.by Gary WellsTech Companies Receive New Avenue to Enjoy the R&E Tax Credit
Early stage technology companies have a new way to convert income tax credits that arise from R&D efforts into payroll tax credits that may immediately benefit the companies.by Greg BryantTrump-Tax-Plan-where-we-going
As we have argued in our previous articles, as the world has globalized and commerce crosses borders more frequently, the current US corporate income tax code is not only obsolete it is suicidal. The time for change is overdue. But what change will we find under President-Elect Trump?by Greg BryantTransfer Pricing Introduction
Transfer pricing is one of the most important issues in international taxation.by Greg BryantCorporate Income Tax Should be Repealed
Over the past year there has been increasing political chatter about tax reform, a topic long overdue and reaching crisis level.
by Brian LemonIRS Increases The Need for Attorney-Client Privilege on Tax Issues
It may come as an unpleasant surprise to some readers to discover the Internal Revenue Service (“IRS”) has been using tax audits as cover for criminal investigations, which can directly relate to the tax issues or to some other federal matter.by Greg Bryant