How to get your offer in compromise approved

What is an offer in compromise, and how do you get one approved? Well, the IRS defines it as a tool that “allows you to settle your tax debt for less than the full amount you owe. It may be a legitimate option if you can’t pay your full tax liability, or doing so creates a financial …

Attorney-client privilege and taxes

It’s not uncommon for attorneys to push attorney – client privilege as a foolproof system that lets their clients say whatever they want. However, as with so many other things, attorney – client privilege isn’t entirely black and white. Previously, we’ve written about how Sovereign Management …

Partnership Tax Audits

Previously, I’ve written how business partners can use the tax code to attempt to, not – so delicately, “screw” a business partner. Thanks to some terrific research by Farley P. Katz, Joseph Perera, and Katy David at Strasburger & Price LLP, it seems, unfortunately, that even more …

The FBAR win that didn’t include an FBAR

A recent tax court case had many of us excited about the government losing an FBAR penalty case and the impact it could have for taxpayers. Unfortunately, upon further review, while the taxpayer deserves congratulations for his impressive and complete win, this particular case was limited in…

What Is an IRS Private Letter Ruling?

  In this episode of our podcast, Parental Advisory, we discuss the advantages and disadvantages of the curious tax procedure know as an IRS private letter ruling.     What is a private letter ruling?   A taxpayer requested private letter ruling (PLR), per the IRS, is "a written statement issued to a taxpayer that interprets and … Read more

Maerki Baumann & Co. added Blacklisted Swiss Bank list

Since our last update on the “blacklisted” Swiss banks, a handful more have been added to the IRS Foreign Financial Institution List, including:

Banque Internationale a Luxembourg (Suisse) SA (effective 11/12/15)
Zuger Kantonalbank (effective 11/12/15)
Standard Chartered Bank …