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EXPATRIATION – ULTIMATE OPT OUT? HASSLE? BOTH?

In International Tax by freemanlawdevLeave a Comment

Every few years, it seems, there’s a story about someone giving up his or her U.S. citizenship or legal residency to save on U.S. taxes. Given the peculiarities of the U.S. tax system, expatriation may make sense, sort of the ultimate opt-out. But there are some hassles involved. The United States is unique as virtually the only country to use citizenship as a …

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A Brave New World: The Panama Papers and the United States’ Role as a Tax Haven

In Fraud, International Tax, OVDP by Jason B. Freeman1 Comment

As published in Today’s CPA Magazine.  For a link to the article, click here. In April of this year, a consortium of journalists released a bombshell data leak—a collection of some 11.5 million records, known as the “Panama Papers,” allegedly linking thousands of people across the globe to a web of secretive shell companies and offshore bank accounts formed through a …

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IRS Adding 700 Enforcement Personnel and Criminal Agents—Audits and Enforcement Activities to Increase

In Audit by Jason B. FreemanLeave a Comment

The IRS is now well into its initiative to add 700 audit and enforcement personnel, in what IRS Commissioner Koskinen recently called the Service’s “first significant enforcement hiring in more than five years.” The new hires are designed to fill key gaps in the IRS’s enforcement workforce that have been created by years of attribution, largely due to budget cuts …

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Internet Tax Freedom: State Taxation and the Internet

In ITFA, State and Local by Jason B. Freeman1 Comment

On February 24, 2016, the President signed into law the Trade Facilitation and Trade Enforcement Act of 2015 (“TFTEA”), which permanently bans state and local jurisdictions from imposing taxes on Internet access or imposing multiple or discriminatory taxes on electronic commerce. The act made permanent a temporary moratorium on such taxes that has been in place—thanks to multiple short-term extensions—since …

Major Changes are in Store for the Partnership Audit Rules

In Partnership Tax, Uncategorized by Jason B. FreemanLeave a Comment

The partnership audit rules are in for a major overhaul. The recently-enacted Bipartisan Budget Act of 2015 (BBA) is replacing the existing partnership audit framework with a new regime. The new rules, however, are not immediately mandatory—they will generally apply “to returns filed for partnership taxable years beginning after Dec. 31, 2017.” So, for many partnerships, now is the time …