2011 OVDI Program Q&A’s Updated by IRS; FBAR Deadline Reminder

On June 2, the IRS updated the Q&A’s describing the 2011 Offshore Voluntary Disclosure Initiative.  The initiative is discussed in more detail in our March 3rd blog post, but generally it is a program that allows taxpayers with undisclosed foreign income or assets to come into compliance for a penalty that is below that which…

Continue reading

Email to someoneShare on Facebook0Google+0Tweet about this on TwitterShare on LinkedIn0Pin on Pinterest0

IRS Focusing Gift / Estate Tax Enforcement on California Property Tax Records

Last month, in court in the Eastern District of California, the IRS asked for permission to serve a “John Doe” summons on the California Board of Equalization to require California authorities to release California property tax records relating to transfers of property for little or no consideration.  If enforced, the summons would require the state…

Continue reading

Email to someoneShare on Facebook0Google+0Tweet about this on TwitterShare on LinkedIn0Pin on Pinterest0

“Poison Pill” Plans Used to Preserve NOLs

In a recent Delaware Supreme Court case, Versata v. Selectica, (10/4/2010 Del. Sup. Ct.) 5 A.3d 586, the court approved Selectica’s use of a net operating loss (NOL) preservation plan. The plan essentially allowed Selectica to issue diluting shares to existing shareholders whenever a new shareholder attempted to obtain more than 4.99% of the shares…

Continue reading

Email to someoneShare on Facebook0Google+0Tweet about this on TwitterShare on LinkedIn0Pin on Pinterest0

IRS Initiates Second Offshore Amnesty Program

On February 8th, 2011, the IRS announced the 2011 Offshore Voluntary Disclosure Initiative for taxpayers with undisclosed income in foreign bank accounts to come forward and get current with their taxes. By coming forward voluntarily, taxpayers can generally avoid criminal prosecution and pay a reduced penalty. To participate, taxpayers must submit several documents and amended…

Continue reading

Email to someoneShare on Facebook0Google+0Tweet about this on TwitterShare on LinkedIn0Pin on Pinterest0