Welcome to TaxBlawg, a blog resource from Chamberlain Hrdlicka for news and analysis of current legal issues facing tax practitioners. Although blawg.com identifies nearly 1,400 active “blawgs,” including 20+ blawgs related to taxation and estate planning, the needs of tax professionals have received surprisingly little attention.
Tax practitioners have previously lacked a dedicated resource to call their own. For those intrepid souls, we offer TaxBlawg, a forum of tax talk for tax pros.
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In IRS examinations, many practitioners encounter situations where the Internal Revenue Service seems to conjure up a set of facts that is divorced from reality. On the collection side, strange as it may sound, the IRS sometimes does this too, by treating the taxpayer as if he has assets he really doesn't.
When a taxpayer is unable to pay his tax in full, he is entitled to request a “collection alternative” from the IRS, usually an Installment Agreement but sometimes an Offer in Compromise. This process involves submitting a variety of financial statements to the IRS – most often ...
As part of its current Offshore Voluntary Disclosure Initiative (“OVDI”), the IRS is strongly encouraging taxpayers against making so-called “quiet” disclosures, in which taxpayers file amended tax returns, pay the applicable taxes and interest, and hope that the IRS doesn’t identify them for further investigation. These disclosures are described as quiet because they involve neither alerting the IRS to the amended returns nor offering to pay any applicable penalties. Because taxpayers may rightfully perceive the 25-percent penalty required to participate in ...
With the IRS’s increasing emphasis on transfer pricing and other tax issues that depend upon economic and scientific concepts and analyses, tax attorneys frequently rely on non-legal professionals to provide expert assistance in areas with which an attorney might not be familiar. While this non-legal expertise helps facilitate the attorney’s representation of her client, the introduction of these non-legal professionals into the attorney-client relationship poses an obvious concern about breaching the attorney-client privilege. Ordinarily, if someone other than ...
Following the Supreme Court’s decision in Mayo Foundation v. United States, in which the Court ruled that tax regulations receive deference from courts under the Chevron doctrine that applies to non-tax regulations, many commentators acknowledged the decision’s anticipated impact on disputes about the validity of tax regulations. The new standard gives the IRS much wider latitude in issuing regulations that fill gaps caused by statutory ambiguities. In our prior discussions of the decision, we speculated:
The IRS may be wise to keep in mind that neither it, nor the courts ...