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Estate Denied Discounts For Marketable Security Family Limited Partnership
The Holliday decision does not make me despair when it comes to marketable security family limited partnerships, but advisors should really push for strong execution.I mean if you are saving near a million or more in transfer taxes, spring for a couple of thousand to get a good general ledger. Have a couple of meetings. And make sure you read that partnership agreement and do what it says.
Time For Sergeants – 1970 – The Xavier Class Lamented By Antonin Scalia- Part II –
The mission of the infantry is to close with the enemy by means of fire and maneuver to defeat or capture him, or to repel his assault by fire, close combat, and...
Sixth Circuit Looking To Protect Taxpayers From IRS Not IRS From Taxpayers
The issues here remind me a good bit of the litigation Cause of Action ran against TIGTA looking for more information. They wanted more details on TIGTA’s investigation of statements by Austan Goolsbee about Koch Industries that hinted that he might have access to information that was protected. TIGTA indicated that revealing more details would, in itself, be an improper disclosure.
IRS Bounty Hunters Should Not Waste Time On FBAR Penalties
The Tax Court’s opinion unfortunately will have a chilling impact on whistleblowers coming forward – especially whistleblowers blowing the whistle on illegal offshore accounts held by millionaires and billionaires. Individuals need to have confidence that when they come forward that they will be awarded if the whistleblower’s information is used by the government and results in collected proceeds.
The good news though is that the Court found that the policy arguments put forward by the National Whistleblower Center in its amicus brief to be well-grounded and reasoned – and the Tax Court stated that Congress could fix the problem. Congress needs to accept the Tax Court’s invitation and immediately clarify the statute that whistleblowers who blow the whistle on offshore tax cheats and other big time tax criminals are entitled to an award.
Becoming Part Of The Regiment – 1970 – The Xavier Class Lamented By Antonin Scalia – Part I
But as you know, the tradtion of Xavier as a thoroughly military academy did not survive the antimilitary sentiment of the Vietnam War. I lamented when the school...
And Then They Came For The Go Masters
I am often surprised by how many people are not at all familiar with the game of Go. It is more ancient that Chess and both easier and harder. It is easier because...
AICPA Versus Block Advisors In Spat I Hope They Both Lose
So why am I just getting out the popcorn rather than taking sides in this conflict? What Block Advisors is promising is giving people access to the type of relationship that many people have with CPAs and EAs and even the occasional preparer, like Bob Flach, the Wandering Tax Pro that earned us the title “Trusted Advisor”. Somebody who knows the tax law in a practical sense and knows and understands you and tailors their practice to your foibles or perhaps practices tough love to get you more organized. If you are ever audited they will defend you tenaciously and if necessary fall on their sword for you. When it works really well they will complement your personality, reassuring the timid and restraining the overly aggressive.
IRS And Liquor By The Wink
This little comedy may seem far removed from the interminable IRS scandal now on Day 1043 by TaxProf Count. We privilege not for profit organizations in a variety of ways, not just through federal tax benefits but also by letting them sell liquor, where others cannot, run gambling, or make significant political expenditures without disclosing donors. There is even an entirely unmerited dose of credibility that organizations get for having achieved exempt status.
Yet we lay the regulation of entities seeking exemption from a variety of rules at the doorstep of our tax collection agency, even when the status has little or no tax significance as was the case with the 501(c)(4) organizations that made up the core scandal and this particular attempt at 501(c)(7) that just wants to serve liquor.
Sales Tax Collection By Out Of State Vendors May End Up At Supreme Court Again
“Why would we continue to work under an antiquated court ruling? Look how old Quill was,” Magee told Tax Analysts in September, echoing an argument state representatives have been making about physical presence for at least the last 15 years. “Times change, and things were once constitutional and they’re not constitutional anymore. It is time for some sort of paradigm shift, and we can’t continue to remain under the Quill ruling.”
Gay Marriage Constitutional Crisis?
There is a little bit of confusion about what Alabama is up to in its response to Obergefell v Hodges, the US Supreme Court decision that affirms the right of people of...