Law Office News
Fundamentals of 1031 Like Kind Exchange: Rules, Pitfalls & Examples
Introduction Section 1031 like-kind exchange of the Internal Revenue Code (IRC) allows taxpayers to defer…
What to Do if the IRS Disallows Your ERC Claim, Assesses Repayment, or Audits Your Business
The Law Office of Anthony N. Verni, Inc. The IRS is now aggressively reviewing Employee…
SUPREME COURT TO DECIDE WHETHER MANDATORY REPATRIATION TAX IS CONSTITUTIONAL WITH RESPECT TO CFC UNDISTRIBUTED INCOME
On June 26, 2023 the Supreme Court granted the Petitioners’ Application for a Writ of…
FORM 5471 FILING REQUIREMENTS FOR U.S. TAXPAYER MARRIED TO NON-RESIDENT SPOUSE
The requirements for filing Form 5471 are quite complex and confusing. The obligation to file…
FATCA REPORTING CHANGES AND INFLATION REDUCTION ACT SPELL TROUBLE FOR TAXPAYERS WHO HAVE FAILED TO FILE FORM 8938 AND FBARS
A recent report (the “Report”) from The Treasury Inspector General for Tax Administration (“TIGTA”) addressing…
FBAR CONSENT TO EXTEND STATUTE OF LIMITATIONS OPERATES AS A WAIVER/NON WILLFUL FBAR PENALTIES ASSESSED PER ACCOUNT
U.S. DISTRICT COURT DECIDES FBAR PENALTY STATUTE OF LIMITATIONS WAIVED AND ASSESMENT OF NON WILLFUL FBAR…
Quiet Disclosures and the Civil Willful FBAR Penalty. Even Death Will Not Help You
The Government will examine efforts by a Taxpayer to avoid detection by the Internal Revenue…
HOW BIDEN’S TAX PROPOSAL WILL IMPACT GIFT AND ESTATE TAX PLANNING
The Biden Tax Proposal, if enacted, will have a significant impact on estate planning for…
TRANSFERRING PROPERTY TO AVOID PAYING TAXES
Why it’s a Very Bad Idea? A taxpayer who owes or anticipates owing a substantial…
UNDERSTANDING THE STATUTUE OF LIMITATIONS
Duration the IRS Has to Assess Federal Income Tax? The statute of limitation for assessment…
Courts Split on FBAR non-willful Penalty
Should FBAR non-willful penalty be charged per form or per account? The Courts have recently…
Cash Intensive Businesses & the IRS; a marriage made in Hell
Cash intensive businesses Operating a cash intensive business is often accompanied by poor record keeping…