Panama Papers: The Case for FATCA Global Adoption

The disclosure of the Panama Papers promises to cause global unrest as exemplified by the recent protests in Iceland.  As more and more leaders...

Keep your sanity during tax season.

There are a lot of pressures surrounding our voluntary tax system. There are deadlines and then there is honesty, to name a couple. What,...

What is a “Willful” Failure to Disclose Offshore Bank Account

This is the central question as to whether a taxpayer enters Offshore Voluntary Disclosure or Streamline.  It also fixes potential penalties under 31 U.S.C....

Blank Receipt – No Tax Deduction for Charitable Contributions

The U.S. Tax Court issued a decision concerning tax deductions of charitable contributions in Thad Deshawn Smith v. Commissioner of the Internal Revenue, October...

Interest Deductible Even On Non-Taxpayer’s Mortgage

I came across this today in passing while working on a tax case. Most homeowners deduct home mortgage interest on Schedule A of their...

Taxation of Artists: Business or Hobby Losses – Tax Tips

Artists typically have financial challenges while they build a market for their artwork.  During the many years of likely tax losses, the IRS might...

Partnership Basis in Contributed Promissory Notes and Guarantees: Tax Tips

Partners of a partnership sometimes contribute promissory notes to the partnership.  As an example, a partner drafts a note payable to the partnership promising...

Nonresidents of Colorado Taxed on Colorado Real Estate

It is a little known fact that if a nonresident of Colorado owns real estate in Colorado, such as a ski condo, the nonresident...

Innocent Spouse Relief Even for the Wealthy

If a taxpayer prevails under the provisions of Innocent Spouse Relief, the taxpayer will be freed of that tax-liability shackle. Tax Attorney (NY Bar,...

Accuracy Related Penalty IRC 6662(a): 5 Tips

5 Tips by Tax Lawyer Philip Falco: Scan all of your receipts and email the questionable expenses to your CPA for review. Keep a...