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Guide to all stages of a tax examination, investigation, litigation and prosecution -- civil or criminal -- including coverage of:
A new extensive analysis of the FBAR (Report of Foreign Bank and Financial Accounts) reporting requirements, the penalties for failing to comply with those requirements, the recent FBAR penalty case United States v. Williams [2010 U.S. Dist. LEXIS 90794 (E.D. Va. 2010)], and the proposed amendments to the FBAR regulations.
The Department of Justice's new guidelines for the forfeiture of attorneys' fees. This is the first time in the Justice Department's history that the Department has articulated specific standards governing a prosecutor's discretion in deciding whether or not to forfeit attorneys' fees. Going forward, it will be critical for all practitioners to be fully familiar with these guidelines in any matter where there is the potential for fee forfeiture.
An analysis of the new codification of the "economic substance doctrine" and how it will change the current standards in civil and criminal tax cases involving tax shelters.
A detailed description of civil tax examinations, including IRS procedures when examining cash intensive businesses and sets forth key strategies for ensuring a favorable audit outcome. It also describes the new "Quality Examination Process," the new requirement for certain taxpayers to identify on their tax returns an "Uncertain Tax Position."
The new standards governing tax practitioners under IRS Circular 230 and IRC Section 6694, and the new American Institute of Certified Public Accountants (AICPA) Statements on Tax Practice governing the practice of accountants effective January 1, 2010.
A comprehensive discussion of the numerous significant amendments to the Tax Court's Rules of Practice and Procedure. These amendments make major changes in the area of discovery, including expanding the opportunities for depositions in Tax Court practice.
The new accuracy-related penalties on transactions that lack economic substance and on undisclosed foreign financial asset understatements, and the recent changes to the IRC Section 6707A penalty for failure to include reportable transaction information on returns.
All aspects of the "Innocent Spouse" defense.
Current and vital information to the tax practitioner about the IRS's new voluntary disclosure program.
