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Ex-Seyfarth Shaw Attorney Case: The Latest in a Series of Department of Justice Prosecutions For Tax Shelter Fraud

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Recently, tax shelters have become the target of much prosecution by the Department of Justice. In the largest criminal tax case ever filed, professional services company KMPG LLP admitted to engaging in fraud and generating at least $11 billion dollars in false tax losses. The multi-billion dollar criminal tax fraud conspiracy involved the elaborate design, marketing, and implementation of fraudulent tax shelters.

Since the 2005 KPMG indictment and subsequent guilty plea, the Department of Justice has continued in its quest to uncover instances of tax shelter fraud. The case of Chicago tax lawyer and former Seyfarth Shaw LLP partner, John E. Rogers, is among the latest in a series of tax shelter fraud criminal prosecutions. Starting in 2010, the U.S. Department of Justice targeted John E. Rogers, ex-Seyfarth Shaw LLP partner, with a civil suit alleging he Read More

Amazon Fulfillment – Customer Convenience or Sales Tax Disaster


Now more than ever Amazon has been a one stop shop for many consumers. Not only can you buy just about anything you can think of on the Amazon website, but you can also receive lightning fast delivery of whatever you buy. Over the past few years, Amazon has taken their company to the next level. Now, in addition to selling items, Amazon provides a fulfillment service to online retailers.

As Amazon puts it, their fulfillment business “helps you grow your online business by giving you access to Amazon’s world-class fulfillment resources and expertise.” Simply put, the online retailer sends their products to Amazon. Amazon stores the item at one of its distribution centers. Once the item is purchased, Amazon packs and ships your product to the customer. In addition, Amazon provides customer support. While it certainly Read More

So What is the FATCA Deadline for Trusts?

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The Financial Times (FT) ran a story on Saturday 18 October about confusion over the Foreign Account tax Compliance Act (FATCA) deadline for trusts. Trustees of private family trusts are being urged to register with the US tax authority or risk non-compliance with new counter-tax avoidance legislation.

Investment-based trusts that are managed by a discretionary fund manager are considered, according to the US tax authority’s definitions, to be “financial institutions” and must therefore meet FATCA requirements.

The first step is to apply for a so-called “global intermediary identification number” or GIIN. Failure to meet FATCA’s reporting obligations could result in a 30 percent withholding tax Read More

Real Housewives Stars Sentenced To Prison

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For reality TV stars Joe and Teresa Giudice, a very different kind of reality awaits them. For years, the stars of New Jersey’s most popular reality TV show enjoyed celebrity-status, celebrating lavishness and self-indulgence before a national audience.

Now, in an epoch fall from grace, they face the reality of a cold, dank prison cell.

At the federal courthouse in Newark last Thursday, October 2, 2014, Joe and Teresa Giudice, two of the more tantalizing characters on Bravo’s “Real Housewives of New Jersey,” were sentenced to 41 months and 15 months, respectively. What for? For unlawfully obtaining millions of dollars in loans and for hiding income and assets in a 2009 bankruptcy filing. Read More

Definition of Willfulness in OVDP Streamline Program Intentionally Left Vague!

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According to the IRS website, Streamlined Filing Compliance Procedures, the streamlined procedures are available to taxpayers certifying that their failure to report foreign financial assets and pay all tax due in respect of those assets did not result from willful conduct on their part.

We previously posted on Wednesday, October 1, 2014, “So What Does “Non-Willful” Really Mean Under The Streamlined OVDP – Take #2” where we discussed that until the IRS gives us their specific interpretation of “Non-Willfulness” under the 2014 Streamline Program; you might want to consult the IRS’s Internal Revenue Manual (IRM) for guidance!

More specifically: Read More

5 “Tricks” To Make Halloween Candy Tax Deductible


You can in fact deduct Halloween candy if you figure out a way to make it business related. The IRS doesn’t say a lot about this topic because they don’t want to give you “permission” to deduct these items, but they also have not specifically stated that you cannot deduct Halloween candy.

Here are five ways to deduct those over-priced bags of snack size chocolates:

1. Make a promotion out of it. Attach your business card or a promotional flyer to packets of M&M’s and voila! Deductible.

2. There are many companies who will print candy wrappers with your logo on it. An even better and more advanced way to promote your business and still have something for Read More

IRS Did Not Conduct 63% of Partnership Audits Correctly!

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The IRS may have failed to follow one or more of the correct procedures for partnership audits in nearly 1,700 examinations in fiscal year 2012, Treasury Inspector General for Tax Administration said in a report released Oct. 22, 2014.

The agency needs to do a better job of making sure its examiners follow the procedures for these audits set out in response to the Tax Equity and Fiscal Responsibility Act, the Treasury Inspector General for Tax Administration (TIGTA) watchdog office said.

Based on a sample of 35 partnership audits subject to TEFRA in FY 2012, auditors didn’t follow one or more of the correct procedures for 22 of them (63%).

Specifically, TIGTA found that: Read More

What Is A Church?

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Churches occupy a distinct place in the tax code of the United States. They are tax exempt, but that is not where the uniqueness lies. Many types of charitable organizations are considered tax-exempt non-profit organizations. Most organizations wishing to obtain tax exempt status must first file Form 1023 (or the new Form 1023EZ) with the IRS, seeking approval as an IRS-qualified tax exempt organization. The unique aspect of a church is that qualifying as tax exempt is automatic if it meets the IRS definition of a 501(c)(3) organization:

1. The organization must be organized and operated exclusively for religious, charitable, scientific, or other charitable purpose.
2. Net earnings may not inure to the benefit of any private individual or shareholder. Read More

10 Top Tips From “The Best Tax Webinar of The Year”

Top Ten Target Means Successful Achievement

The feedback from in the “Best Tax Webinar of The Year” was extraordinary as we drew more than one thousand attendees. Many asked for a copy of the presentation and we are now producing a better version for those who attended and those who wanted to attend and were unable to do so. As a result, we are now in production with a 30 minute video presentation that will be available in a week covering the following topics:

1. How to gain authority over millions of pages of tax professionals on the web in one day

2. How to move your tax reputation to viral status; we discovered this secret when we noticed thousands of visitors going to one of our members profile page

3. How tax professionals are landing the biggest tax clients and tax jobs of their careers Read More

Ireland’s Plan To Close A “Double Irish” Tax Loophole Could Cost Google And Apple Billions of Dollars

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Following pressure from the United States and EU, the Dublin government said it planned to change a rule underpinning this system which allows a company to be registered in Ireland but not resident there for tax purposes. In his budget, Ireland’s Finance Minister Michael Noonan has also announced changes to the intellectual property tax regime in the hope of keeping Ireland an attractive destination for business.

Ireland’s plan to close a “Double Irish” tax loophole could cost U.S. companies including Apple and Google billions of dollars. Analysts and tax advisers predict that corporations which need access to the EU’s 500 million consumers will find it difficult to set up equally effective schemes in other member states. Read More

My Halloween Nightmare – How I Almost Lost My Identity And Money To A Fake IRS Agent

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With Halloween coming up, it is just not the neighbor kids looking forward to trick or treat but also people pretending that they are the Internal Revenue Service looking to steal your identity and scam you for your money.

Listen to the story of Arati who works in New York City and immigrated to the U.S. from India. Arati received a call from a Brian Cruz who called her house early in the morning before Arati left for work. He left his telephone number, name and noted he was calling from the IRS. Arati put the number in her cell phone without searching for it online first. After all it had a 202 area code which is Washington D.C. so she figured it had to be official. Once she got into her car she called, and the man who picked up the call answered that this was the investigations bureau for the IRS. Arati asked for Cruz, but he Read More

Tax Time – Why We Pay

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It began with an earthquake. What hit San Francisco in 1906 was one of the worst natural disasters in American history. Once the water mains broke, there was no way to fight the dozens of fires caused by ruptured gas mains, except by dynamiting buildings in the fire’s path, which made things worse. People raced to the San Francisco Bay and boarded ferries to escape the flames. The fires lasted for days. A handful of men rushed to the banks, but before long all that was left of the city’s deposit and lending institutions, aside from rubble and ashes, were their fireproof steel vaults: red hot, smoking, and locked. More than 3,000 people died, including the city’s fire chief, who fell two stories after the dome of the California Hotel crashed into the fire station. Most of the city was destroyed.

Economic aftershocks were felt as far away as London. Twelve insurance companies Read More