Author Archives: Patricia Weisgerber

International Tax Issues Are A Major Focus of Newest Launch of IRS Compliance Campaigns in 2017

by Attorney Patricia Weisgerber, LL.M. Earlier this year, the IRS Large Business and International division (LB&I) rolled out 13 compliance campaigns[1] to target both individual taxpayers and corporations for examinations on certain tax compliance issues. On November 3, 2017, IRS announced the identification of an additional 11 compliance campaigns ...

Are Your Business Deductions at Risk of Being Disallowed by the IRS?

by  Attorney Patricia Weisgerber, LL.M. Small businesses run on tight margins. The last thing a business owner wants is an IRS notice announcing the disallowance any of their business expense deductions. This is particularly the case for sole proprietorships who report their business expenses on Schedule C of IRS Form 1040. For ...

UPDATE: MTC Extends Deadline for Amnesty under the Online Marketplace Seller Voluntary Disclosure Initiative

Earlier today, the Multistate Tax Commission (MTC) released an update extending the October 17, 2017 deadline for businesses to file under its Online Marketplace Seller Voluntary Disclosure Initiative. The new deadline is now November 1, 2017. This initiative is specifically for businesses who are online marketplace sellers using a marketplace provider/facilitator ...

An Overview of the Unified Republican Framework on Tax Reform

On September 27, 2017, President Trump and the Republicans unveiled the elements of their tax reform framework. Here’s a quick overview of some of the proposed changes: Individual Taxes Standard Deduction: Under the proposed framework, that standard deductions will approximately be doubled to:
  • $24,000 for married taxpayers filing jointly, and
  • $12,000 for single
...

Tax Relief for Hurricane Harvey and Irma Victims

The IRS is offering tax relief for taxpayers affected by Hurricanes Harvey and Irma. This relief is automatic for those taxpayers located in designated disaster areas. These areas include Florida, Georgia, Puerto Rico, the Virgin Islands and parts of Texas. In general, the IRS is providing extensions until January 31, 2018 ...

The Importance of Timely Electing Your Foreign Earned Income Exclusion

by Attorney Patricia Weisgerber, LL.M. Life as an American living abroad can conjure idyllic notions of painting en plein air in Paris or negotiating a last minute deal in Brussels. Not so idyllic, however, is the reality of filing U.S. tax returns from overseas. One of U.S. taxpayers living abroad is ...

SCORE! for the Boston Bruins – Jacobs v. Commissioner

by Attorney Patricia Weisgerber, LLM Like Napolean recognizing that an army marches on its stomach, the owners of the Boston Bruins know a hockey team needs to be well-fed to ensure optimal performance on game day. So, when the Bruins go on the road to play away-games, management plans ahead. With ...

FBAR Penalties Now Adjusted for Inflation: Abatement/Mitigation Still Possible

If you haven’t filed your Report of Foreign Bank and Financial Accounts (FBARs) on a timely basis, you could be at risk of a higher civil penalty assessment. Inflation-adjusted FBAR penalties are now in effect. New FBAR Civil Penalties Framework The statutory civil penalties most people are familiar with, and as reflected ...

2017 OVDP Declines and Withdrawals Campaign: Certain U.S. Taxpayers at Risk of Audit

In 2016, the Treasury Inspector General for Tax Administration (TIGTA) released a report which assessed how well that IRS was managing the Offshore Voluntary Disclosure Program (OVDP). OVDP is one of the programs taxpayers may use to become compliant if they previously had failed to report offshore income on their ...

Taxpayer Tips: Best Practices for U. S. Tax Court

Taxpayers contesting IRS assessments of additional taxes, penalties and interest have a number of different options to contest and appeal those assessments. One of those options includes bringing a case to the United States Tax Court (Tax Court). Here are some Tax Court practice tips for taxpayers:

1. Know What Tax ...