First Steps to Establishing Your New Business: Know Your Business Taxes!

Your company is responsible for various types of business taxes, and if you don’t comply you could be assessed hefty tax penalties and you risk possible litigation with the IRS. What types of business taxes are there? There are five general categories of business taxes: (1) Income tax, (2) estimated...

IRS Blocks SALT Cap Workarounds

Attempts to Circumvent $10,000 SALT Cap Blocked The U.S. Treasury Department recently issued a new regulation stating that taxpayers cannot claim that they made a charitable contribution if they received a state tax credit in exchange for a “gift” to a state fund. This rule effectively blocks state proposals aimed...

A Few Words on President Trump’s New Supreme Court Pick

Immediately following Justice Kennedy’s July 31, 2018 announcement of his retirement, Brett Kavanaugh, a prominent conservative D.C. Circuit Court judge, received a call from the President. This marks Donald Trump’s second opportunity to appoint a Supreme Court Justice. Since his nomination on July 9, 2018, Kavanaugh has been the subject...

Taxpayer Win: Failure to File Accurate FBAR Deemed Not Willful, Part IV

The story of Arthur Bedrosian, CEO of Lannett Company, Inc., and his Swiss bank accounts shows how a taxpayer’s cooperation with an IRS investigation and the court’s belief in the taxpayer’s honesty can be significant factors in the outcome of an FBAR penalty case. In Part III, we provided an...

Taxpayer Win: Failure to File Accurate FBAR Deemed Not Willful, Part III

Before the Offshore Voluntary Disclosure Program (OVDP), it was rare for a taxpayer to pay penalties when they voluntarily came forward with information regarding their foreign accounts. Most tax practitioners, therefore, recommended that their clients do a “quiet” disclosure, which involved simply amending their previous years’ returns, and paying any...

Taxpayer Win: Failure to File Accurate FBAR Deemed Not Willful, Part II

In Part I, we described the background of Bedrosian v. United States, 3d Cir., No. 17-3525, in which the CEO of a pharmaceutical company was pursued for willful FBAR penalties. The IRS didn’t go after Arthur Bedrosian for his many years of noncompliance with foreign reporting obligations, but rather for...

Taxpayer Win: Failure to File Accurate FBAR Deemed Not Willful, Part I

The IRS aggressively pursues taxpayers for FBAR noncompliance, but in this case it may have overreached its boundaries. CEO takes bad advice Arthur Bedrosian is currently Chief Executive Officer of Lannett Company, Inc., a manufacturer and distributor of generic medications. In the early days of his career (1970s) he frequently...

Government Regulation of Cryptocurrency

Governments throughout the world have begun developing regulations for cryptocurrency exchanges. In this post, we will provide an overview of how various U.S. government agencies view cryptocurrencies and what they are doing to prevent their misuse. The Internal Revenue Service Digital currency = property In 2014, the IRS issued Notice...