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Ordinary Business Care and Prudence Standard is a requirement that is present, explicitly or implicitly, in all reasonable cause defenses. In this article, I would like to explain what Ordinary Business Care and Prudence Standard means and what are the main factors for analyzing whether a taxpayer met the burden of proof required under the […]
In today’s world connected through an invisible network of new technologies, a great number of persons prefer to choose an attorney based on his qualities rather than his state of residence. The residents of Madison, Wisconsin, similarly search for such an attorney, especially in the area of Streamlined compliance procedures by utilizing the search words: […]
Despite their apparent diversity and complexity, international business transactions can be grouped into three categories: export of goods and services, licensing and technology transfer and foreign investment transactions. International Business Transactions: Export of Goods and Services The first category of international business transactions consists of exports involving a sale of a commodity, manufactured goods or […]
We are continuing our series of articles on Reasonable Cause. Today, we will discuss whether a serious illness can establish a reasonable cause for abatement of the IRS penalties. It is important to note that this discussion of serious illness as a reasonable cause is equally applicable to death and unavoidable absence of the taxpayer […]
On December 14, 2016, Credit Suisse and Italy settled their dispute over Credit Suisse undisclosed offshore accounts owned by Italian tax residents. The settlement between Credit Suisse and Italy was approved by a judge in Milan and obligates Credit Suisse to pay a total of 109.5 million euros – 101 million euros in taxes, interest […]