IRS Power to Reallocate Income, Deductions, and Other Items under IRC Section 482
Some taxpayers may be tempted, especially in situations involving related parties, to arbitrarily shift the source of income or allocation of deductions, in order [...]
Voluntary Disclosure of Foreign Accounts and Foreign Assets in 2012
This article offers an important strategic perspective on the foreign financial accounts disclosure in the year 2012. In particular, it appears that, this year, [...]
Form 5472 Penalties
In a previous article, we covered the basics of the IRS Form 5472. In this article we will explain the penalties that may apply [...]
Classification Conversion of A Tax-Exempt Organization: 501(c)(6) and 501(c)(3) Organizations
In a previous article, I already discussed some of the major differences between 501(c)(3) and 501(c)(6) organizations. However, this discussion was limited to characteristics [...]
Offshore Voluntary Disclosure Program 2012: Impact of Form 8938
The announcement by the IRS of the opening of the new Offshore Voluntary Disclosure Program (OVDP) on January 9, 2012 came as a surprise [...]