THE VOLUNTARY DISCLOSURE OF UNREPORTED OFFSHORE ASSETS
May 05, 2015
In his essay titled “Prudence,” Ralph Waldo Emerson proposed that “[i]n skating over thin ice our safety is in our speed.” Taxpayers with unreported offshore assets are certainly “on thin ice” in term...
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REGULATING THE CONDUCT AND ETHICS OF TAX PROFESSIONALS
Apr 08, 2015
This article explains the reciprocal nature of the ethical requirements governing all Tax Professionals. It also explains a taxpayer’s rights when confronted with unethical and inappropriate conduct....
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DE NOVO REVIEW OF ASSESSABLE INTERNATIONAL PENALTIES
Apr 07, 2015
Many taxpayers and tax professionals mistakenly believe that Collection Due Process (“CDP”) rights do not attach to international information return penalties. Introduction Many taxpayers and tax prof...
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NONTRADITIONAL TAX ADVOCACY - CONSTITUENT SERVICES & CONGRESSIONAL INQUIRIES
Apr 07, 2015
Tax advocacy traditionally occurs at the agency level and in the tax courts, where taxpayers benefit from (costly) professional representation. However, a Congressional Inquiry is an inquiry that is...
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