Rescued From The Brink of Insanity: OVDP and Double Counting
What is this phenomenon known as double counting? Why is it important? If you are shepherding clients through the OVDP program (or through streamlined domestic), or you are going through the program yourself, it is critical that you understand what it means and the governing principles behind it. Otherwise, you could be paying an offshore […]
Is that Worker An Employee? Part 2 – Requesting a Tax Court Determination [Webinar]
This is the last part of my presentation on, “Is that Worker An Employee? Questions and Answers on Worker Classification.” The topic is “Requesting a Tax Court Determination.”
IS THAT WORKER AN EMPLOYEE? QUESTIONS AND ANSWERS ON WORKER CLASSIFICATION [Webinar]
Course Description If you own or manage a business that uses independent contractors, you need to know when you can or cannot treat a worker as an independent contractor. This presentation answers some of the common questions about worker classification. INTRODUCTION Misclassification of employees as independent contractors is now a common phrase uttered by state […]
On the Brink of Insanity: How to Calculate the Miscellaneous Offshore Penalty under the Streamlined Domestic Procedures
Instructions for Making a Streamlined Domestic Offshore Submission [Podcast]
A Logical Program Made Unnecessarily Complicated: The IRS’ Approach to International Information Returns
I wish to graciously acknowledge the work of Phillip J. Colasanto, Esq. from the law firm of Agostino & Associates, P.C. whose keen insight and innovative thinking as reflected in his article entitled, “The International Information Reporting Penalties: Is the IRS’s Failure to Embrace a One-Stop Shopping Paradigm Inefficient and Statutorily Deficient?,” has proven invaluable. His guidance […]
Eggshell Audits: Don’t Get Cracked [Podcast]
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Eggshell Audits: Don’t Get Cracked
In this episode I discuss eggshell audits and what to do when it comes to filing returns for tax periods subsequent to periods under examination.
The Changing State of Voluntary Disclosure
A new year brings with it many things, including, of course, news and updates from the IRS. As tax year 2019 draws closer, it’s time to start thinking about the many changes to come, like the IRS’ recently published updates to the 2018 OVDP and Voluntary Disclosure rules. As with most situations regarding the IRS, nothing stays […]
After the Dust Settles: Civil Tax Considerations Post-Conviction
In this podcast, I discuss the important inter-connections between civil tax and criminal tax.