Monthly Archives: August 2011

OFFSHORE UPDATE: NEW INDICTIMENTS & SWISS PROBE, FATCA GUIDANCE, EXTENDED DUE DATE FOR OVDI 2011 ADMISSION AND FinCEN FINE IMPOSED

Posted on August 31, 2011 by taxpenaltylawyer

Latest indictment: Another Swiss Banker falls: On August 2, another former Swiss Banker was indicted in the U.S., charged as an enabler, assisting 9 named wealthy U.S. taxpayers to evade U.S. taxes by hiding assets in a smaller Swiss bank … Continue reading →

Posted in 2011 OVDI, COMPLIANCE, TAX, TAX CRIMES | Leave a comment

IRS NOTICES ARE FRUSTRATING AND RESPONDING TO THEM REQUIRES CARE AND ATTENTION TO DETAILS

Posted on August 26, 2011 by taxpenaltylawyer

 A report issued on July 6, 2011 by the Treasury Inspector General for Tax Administration (TIGTA) concludes as did the National Tax payer Advocate that IRS correspondence functions need improvement.  Without a study any professional who deals regularly with IRS … Continue reading →

Posted in COMPLIANCE, IRS COLLECTIONS, TAX, Uncategorized | Leave a comment

WARREN BUFFETT SOUNDING LIKE TEDDY ROOSEVELT

Posted on August 16, 2011 by taxpenaltylawyer

In Op Ed published in the New York Times billionaire, chairman and CEO of Berkshire Hathaway, Warren Buffett has thrown some coal on the fire of the debate regarding tax reform.  To the likely chagrin of Tea Party adherents, he … Continue reading →

Posted in POLICY, TAX | Leave a comment

TAX MEMO DECISION ON BUSINESS VALUATION IS INSTRUCTIVE

Posted on August 15, 2011 by taxpenaltylawyer

While Tax Court Memorandum Decisions may not be cited as precedent the case of Estate of Louise Paxton Gallagher v Commissioner (T.C. Memo 2011-148), dealing with an estate tax valuation, is instructive in summarizing some Tax Court as well as Judge … Continue reading →

Posted in BUSINESS VALUATION, TAX | 1 Comment

AMERICAN PIE TURNS INTO AMERICAN BLACK EYE

Posted on August 10, 2011 by taxpenaltylawyer

Standard and Poor’s downgrade of US debt rating by one notch from AAA to AA+ is a hugely important event.  Not that interest rates will sharply rise anytime soon, not that the U.S. will ever default on its bonds – … Continue reading →

Posted in POLICY, TAX | Leave a comment