New data show that budget cuts to the Internal Revenue Service (IRS) in the past few years has led to a decreasing likelihood that individual taxpayers will be audited. For average taxpayers, the chance of being audited has dropped 23% in recent years, a number that closely follows the inflation-adjusted 17% drop in the IRS […]

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On March 31, a Swiss asset manager appeared before Judge Sidney H. Stein of the US District Court for the Southern District of New York, where he pleaded guilty to charges that he aided his American taxpayer clients and others in schemes to conceal millions of dollars in offshore accounts from the Internal Revenue Service […]

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On March 30, the US Department of Justice (DOJ) announced that the Swiss bank BSI SA had agreed to pay $211 million to the US in order to avoid prosecution for helping Americans evade taxes. The bank is the first Swiss financial institution to reach such a deal, which also requires it to disclose how […]

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Some taxpayers and tax advisors think that the FTB professionals are simply not as nice as the professionals at the IRS, and that is the reason why dealing with the FTB is more difficult.  That is simply untrue.  The overwhelming majority (probably 99%) of all the people who work at both agencies are nice, thoughtful […]

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How to Best Pass Assets to Your Children

by Bruce Givner on April 7, 2015

In their estate plan some parents want their children to get the assets, after both parents are gone, immediately.  Other parents want to have the assets held in a perpetual trust for the maximum estate tax and creditor protection.  The vast majority of parents decide on a variation of “birthday” clauses, e.g., 1/3rd at ages 25, […]

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On March 23, Judge Kathleen Kerrigan of the US Tax Court ruled that, because Midwest Eye Center, S.C. failed to produce any comparable salary data or the method for computing a 2007 bonus paid to the company’s sole shareholder and officer, the Tax Court would uphold corporate tax deficiencies and an accuracy-related penalty assessed by […]

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On March 23, Judge Mark V. Holmes of the U.S. Tax Court ruled that Henry and Christie Metz, owners of Silver Maple Farm (SMF), satisfied all the requisite characteristics of business-owners who intended to earn profit from their venture. The couple’s failure to report income from the sale of a farm property in 2004 was […]

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In a settlement reached with the Internal Revenue Service, a Colorado medical marijuana dispensary will not have to pay a penalty for failing to pay certain taxes electronically. The dispensary, Allgreens LLC, failed to pay employee withholding taxes electronically as is required under federal law due to the fact that it couldn’t get a bank […]

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During a February 24 webcast hosted by the American Bar Association, an Internal Revenue Service (IRS) official declined to provide further definition on “willful” versus “non-willful” behavior for taxpayers hoping to enter the agency’s streamlined version of the Offshore Voluntary Disclosure Program (OVDP). John C. McDougal, a senior special trial attorney in the IRS Office […]

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Protect Your Assets with a Private Retirement Plan

by Bruce Givner on February 26, 2015

The following post was taken from our February 2015 newsletter. Click here to subscribe to our monthly newsletter. Most people will not spend a penny today to put a hurdle between their valuable assets and some currently unknown, but possible, future creditor*.  So what happens is people come to us when there is already a problem.  […]

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