With one of the most well-respected tax controversy practice groups in the country, Baker Hostetler has put together the Issues In Tax Controversy blog. Taking advantage of their expertise in this field, the firm has tapped James Mastracchio and Jeffery Erney to edit this blog on tax controversy and fraud, along with a host of other topics related to tax enforcement.
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Colorado Court of Appeals Releases Significant Decision Affecting Colorado Conservation Easement Litigation
Posted by Jennifer BendaOn March 15, the Colorado Court of Appeals issued its much anticipated decision in Kowalchik v. Brohl. The Court determined that transferees who purchased conservation easement credits from donors of conservation easements were not required to be joined in the...
IRS Releases a YouTube Video Announcing its Voluntary Classification Settlement Program to Employers
Posted by Chris PelkeyThe Internal Revenue Service apparently is using innovative and creative ways to reach out to taxpayers. Recently, the IRS released a YouTube video introducing its Voluntary Classification Settlement Program (“VCSP”). The video is aimed at employers who...
Posted by Jennifer BendaThe HIRE Act of 2010 enacted Section 6038D which requires single taxpayers to report ownership of specified foreign financial assets which in aggregate exceed $50,000 on new Form 8938, which is filed with an individual’s Form 1040. Various dollar thresholds apply...
Posted by Allen LittmanBaker Hostetler’s lawyers have handled hundreds of voluntary disclosures through the 2009 and 2011 Offshore Voluntary Disclosure Programs (OVDI). Recently, the IRS has announced a third OVDI, this time with no defined termination date. The OVDI programs provide...
Posted by Jennifer BendaThe IRS formal program for making voluntary disclosures of offshore accounts and unreported foreign income has been reopened. This is the third in a series of voluntary disclosure programs announced by the IRS. This newest program reinstates fixed penalty amounts...
Posted by Jeffry ErneyThe Voluntary Classification Settlement Program (VCSP) allows employers the opportunity to reclassify workers from non-employees or independent contractors to employees, while making only a minimal payment for potential past employment tax obligations. To be...
Posted by Jennifer BendaWhen and why are clients' discussions with their tax accountant and their tax attorney protected as confidential and privileged? Is there a difference between the discussion that a client should have with their accountant versus their attorney? Why does the law treat these...
Posted by James MastracchioToday, the IRS announced an extension until November 1, 2011 for taxpayers who did not file TD F 90-22.1 (FBARs) forms in prior years. For those taxpayers who only had signatory authority over a foreign account and did not own the account in 2009 or prior...
Posted by Jennifer BendaColorado's recently enacted Taxpayer Amnesty program is provides a one-time opportunity for non-compliant taxpayers to file overdue returns and become compliant. The program covers many types of tax and provides for a waiver of penalties and one-half of the interest...
Posted by Edward BeckwithOrganizations formed to support particular political candidates often achieve favorable tax status as political action committees (“PACs”) and those formed to focus on particular causes can be formed as charitable organizations. Both are exempt from most...