By Phil Karter In a high profile summons enforcement case brought by the Internal Revenue Service against Coinbase, Inc. (United States v. Coinbase Inc., No. 3:17-cv-01431 (N.D. Cal. 2017)), a virtual currency exchange for traders of popular digital cryptocurrencies like Bitcoin, Ethereum and Litecoin, the Internal Revenue Service sought the production by Coinbase of all of its customer records … Continue reading Taxpayers With Unreported Cryptocurrency Gains Should Start Thinking About Filing Qualified Amended Returns – And Soon
All taxpayers, whether individuals or not, may deduct as business expenses the costs relating to tax matters that are ordinary and necessary in the conduct of their trade or business under Section 162 of the Internal Revenue Code. However, certain non-business expenses are also deductible under Section 212, "Expenses for production of income." Notwithstanding the … Continue reading New Tax Bill May Eliminate Right to Deduct Fees Expended “In Connection with the Determination, Collection, or Refund of any Tax”
By Phil Karter The Quality Stores employment tax refund case was argued before the Supreme Court on January 14, 2014. An explanation about the issue at stake can be found in prior Taxblawg.net postings. Although the outcome of the case remains in doubt, the possibility of a taxpayer victory means that employers should start thinking … Continue reading Quality Stores Day Of Reckoning Draws Near – What Should Employers Be Thinking About?
By Phil Karter Is the IRS getting closer to ferreting out “quiet disclosures” by taxpayers who chose that route to address the problem of previously unreported offshore accounts rather than by participating in the Service's offshore voluntary disclosure program (OVDP)? That’s the conclusion of an increasing number of tax professionals and if taxpayers in this … Continue reading Are Quiet Disclosures of Offshore Accounts Becoming Even Riskier?
By Phil Karter Senator Carl Levin (D-Mich.) may have tried to take a bite out of Apple (AAPL) in congressional hearings last May examining the company’s overseas tax structure, calling it “the holy grail of tax avoidance." However, it appears that more than just Irish eyes are smiling on the company these days, for in … Continue reading Apple’s Double Irish With A Dutch Sandwich Goes Down Easy with SEC
For my fellow procrastinators whose federal tax returns are on extension, with the October 15th deadline rapidly approaching, perhaps the burning question has crossed your mind, “If I file electronically while the government is shut down, will my return be accepted?” Yes, I can happily report that a return electronically submitted to the IRS at 3:43 … Continue reading Filing Tax Returns During the Silly Season
By Phil Karter The U.S. Supreme Court today accepted the government's petition for certiorari in United States v. Quality Stores (Civil No. 10-1563, 6th Cir. 2012), a case in which the Sixth Circuit affirmed a lower court’s decision that supplemental unemployment compensation benefit (SUB) payments are not taxable as wages and are consequently exempt from FICA taxes. In accepting … Continue reading Supreme Court Accepts Certiorari In Quality Stores