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Posts Tagged Milwaukee tax lawyer

Proving Willfulness in FBAR Penalty Cases

[Ed. Note - several days ago we wrote a post about willfulness as it relates to FBAR penalties. That article gave specific examples of what constitutes willful behavior. Since that post was written, we received several inquiries regarding the legal standards. Readers interested in this topic should read both posts.] As regular readers of this [...]

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Do You Have The Right To Rely on IRS Forms? Court Says “Maybe” – FBAR Post

A federal jury in South Bend, Indiana convicted James Simon of filing false tax returns and of failing to file FBARs. As regular readers of this blog know, the willful failure to file an FBAR is a felony. Following his conviction, Simon appealed. In a lengthy opinion, the US. Seventh Circuit Court of Appeals upheld [...]

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Tax Reform – Has The Time Finally Arrived?

Earlier this week while sipping wine at the Milwaukee Public Market I sat next to policy wonk from a DC think tank. With the National Governors Association in Milwaukee, lobbyists from around the nation are in town. Predictably, our conversation soon turned to the economy and tax reform. Once again the talk of tax reform [...]

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IRS Seeks To Tax “Stateless Income” – Business Tax Post

Here is a new term for you, “stateless income.” Thought to have been coined by a Congressional staffer in 2007, the IRS has apparently adopted the term – and the cause. Stateless income occurs when a company structures itself such that its profits are not taxed in any jurisdiction. An IRS deputy chief counsel announced [...]

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