The U.S. Tax Court granted a whistleblower’s motion to proceed anonymously in his whistleblower case. The basis: The social interests of protecting his identity as a confidential informant exceeded those of the people’s right to know. But the Court said that, as the whistleblower action proceeds, the balance of social interests may change and his […]
When businesses dispose of assets, gain or loss must generally be recognized on tax returns, depending on the nature of the disposition (by sale, exchange, or involuntary conversion). In a private letter ruling, the IRS approved how a Formula 1 auto racing team handled its auto parts disposition for gain and loss purposes. Due to […]
U.S. citizens must generally file a Report of Foreign Bank and Financial Accounts (FBAR) if they have an account in a foreign country and meet certain requirements. Failure to file an FBAR can result in penalties as high as the greater of $100,000 or 50% of the unreported balance if the failure was willful. When […]
In a Revenue Procedure, the IRS has formally created the Small Business/Self Employed (SB/SE) Fast Track Settlement program to provide an expedited format for resolving disputes with SB/SE taxpayers. It can be used to resolve both factual and legal issues, and may be initiated at any time after an issue is fully developed. One of […]
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