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On May 15, 2019, a Texas federal court ruled that the IRS can enforce John Doe summons for client information from Taylor Lohmeyer Law Firm because the firm failed to demonstrate that the attorney-client privilege protected this information. This is bad news for Taylor Lohmeyer Law Firm clients who now may have to face a […]
A large number of US taxpayers own Panamanian bank accounts. These taxpayers have bank accounts in Panama for a variety of reasons: personal, business, tax planning and/or estate planning. Many of these account holders still do not realize that their Panamanian bank accounts may be subject to numerous reporting requirements in the United States. In […]
On October 30, 2018, the IRS Large Business and International division (LB&I) has announced five additional compliance campaigns. Let’s discuss in more detail these October 2018 IRS compliance campaigns. October 2018 IRS Compliance Campaigns: Background Information By the middle of the 2010s, the IRS realized that the then-existing structure of the LB&I was not the […]
Employee stock option sourcing rules govern the US tax classification of income generated by stock options as US-source income or foreign-source income. In this article, I will provide a general overview of the employee stock option sourcing rules. Employee Stock Option Sourcing Rules: Importance of Income Sourcing Rules Income sourcing rules are very important in […]
On September 10, 2018, the IRS Large Business and International division (“LB&I”) announced the creation of another five compliance campaigns. Let’s explore in more depth these September 2018 IRS Compliance Campaigns. September 2018 IRS Compliance Campaigns: Background Information Since January of 2017, the IRS has been regularly adding more and more compliance campaigns. The compliance […]