By Jonathan Prokup During a course that I taught about tax treaties at last week’s TEI Houston Tax School, one audience member asked whether the exchange-of-information provisions of U.S. tax treaties apply not only to the federal government but also to state and local governments. I had to confess that I did not know the … Continue reading Can Foreign Governments Obtain Taxpayer Information From State and Local Revenue Agencies?
As noted by Janet Novack at forbes.com, Judge England of the District Court for the Eastern District of California last week issued an order permitting the IRS to serve a "John Doe" summons on the California State Board of Equalization. The summons seeks the names of residents who transferred property to relatives for little or … Continue reading The IRS Can Summons California For Property Transfer Records
By Jonathan Prokup As discussed in a story in this morning's Tax Notes, the IRS intends to begin requesting electronic files as part of taxpayer examinations so that it can analyze the "metadata" contained in those files. Metadata, sometimes referred to as "data about data," generally shows information about a computer file, such as its … Continue reading The IRS Wants Your Metadata; Who Else Might Want It, Too?