The Tax of Life

  • All Topics
  • Contributors
  • About
  • Contact
  • Subscribe
You are here: Home / Archives for Tax Controversy

A Day of Reckoning for Recalcitrant Taxpayers?

January 25, 2018 by Rahul Ranadive

Following disclosures by UBS whistleblower Bradley Birkenfeld, the IRS launched an aggressive enforcement campaign against undeclared offshore income and financial accounts in 2009. Over time, it has offered a series of compliance programs to give taxpayers with undeclared offshore accounts the opportunity to make voluntary disclosures regarding offshore income and accounts in exchange for fixed civil penalties and the assurance that criminal penalties would not be ... Keep Reading »

Filed Under: Federal Income Tax, International Tax, Tax Controversy

Statute of Limitations and International Reporting Obligations – Be Sure to Close the Door!

August 29, 2017 by Larry Kemm

When it comes to federal tax matters, an important aspect of risk management includes making sure that the statute of limitations on tax assessments will expire.  This is particularly important for tax years where there is a potentially contentious issue or debatable reporting position taken on the treatment of a material item.  However, increasing reporting burdens imposed on international activities coupled with exceptions to the statute of limitations heighten the ... Keep Reading »

Filed Under: Federal Income Tax, International Tax, Tax Controversy

District Court Doesn’t Apply Economic Substance Doctrine to Transaction Where Taxpayer’s Sole Motive Was Tax Avoidance

August 8, 2017 by Richard Euliss

Judge Schiltz of the U.S. District Court of Minnesota recently issued an opinion in Wells Fargo & Co. v. United States, that qualifies as a key development in the law of economic substance. Taxpayers have battled the government for decades over the precise contours of the judicially-created doctrine often advanced by the government and employed by the courts to deny tax benefits of particular transactions that comply with the strict terms of the Tax Code, but which ... Keep Reading »

Filed Under: Federal Income Tax, Tax Controversy

  • « Previous Page
  • 1
  • 2

Carlton Fields Logo

A blog focused on recent developments in tax law by the attorneys of Carlton Fields.

Focused Topics

  • Employee Benefits
  • Estate and Gift Tax
  • Federal Income Tax
  • International Tax
  • LLCs and Partnerships
  • Qualified Opportunity Zone
  • State and Local Tax
  • Tax Exempt Organizations
  • Tax Controversy

Recent Articles

  • How to Prepare for the IRS’s “New 90-Day Pre-Examination Compliance Pilot” Audit Process
  • COBRA Deadlines and Proofs of Mailing in Carter v. Southwest Airlines Co. Board of Trustees
  • Midyear Premium Increases and Cafeteria Plan Rules

Get Weekly Updates!

Receive articles straight to your inbox, every Monday at 8:00 A.M.

Carlton Fields

  • carltonfields.com
  • Practices
  • Industries
  • ExpectFocus Magazine

Related Practices

  • Taxation
  • Tax Litigation and Controversy

About Tax of Life

  • All Topics
  • Contributors
  • About
  • Contact
© 2014–2023 Carlton Fields, P.A. · Carlton Fields practices law in California as Carlton Fields, LLP · All Rights Reserved · Privacy Policy · Disclaimer

Carlton Fields publications should not be construed as legal advice on any specific facts or circumstances. The contents are intended for general information and educational purposes only, and should not be relied on as if it were advice about a particular fact situation. The distribution of this publication is not intended to create, and receipt of it does not constitute, an attorney-client relationship with Carlton Fields. This publication may not be quoted or referred to in any other publication or proceeding without the prior written consent of the firm, to be given or withheld at our discretion. To request reprint permission for any of our publications, please contact us. The views set forth herein are the personal views of the author and do not necessarily reflect those of the firm. This site may contain hypertext links to information created and maintained by other entities. Carlton Fields does not control or guarantee the accuracy or completeness of this outside information, nor is the inclusion of a link to be intended as an endorsement of those outside sites. This site may be considered attorney advertising in some jurisdictions.