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Articles

What's Your Alien Tax Status and How Does It Affect Investment Property?

By: Eli S. Noff, Esq., CPA, Partner
Mary Lundstedt, Esq., Associate
Brent Conrad read more

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IRS Actively Targeting Taxpayers for Passport Denial/Revocation - Notice CP508C

By: Eli S. Noff, Esq., CPA, Partner & Mary Lundstedt, Esq., Associate read more

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United States V. Garrity: Clarifies Standard of Proof and Establishing Willfulness in FBAR Context

By: Eli Noff, Partner and Mary Lundstedt

On April 3, 2018, in United States v. Garrity, the U.S. District Court for the District of Connecticut considered the Government's suit to reduce to judgment a willful Report of Foreign Bank and Financial Accounts (FBAR) penalty and determined that: (1) the burden of proof is preponderance of evidence, and (2) proof of reckless conduct is sufficient to establish willfulness.1 Now, even the standard of proof required for civil tax fraud is higher than that required for proving a willful FBAR violation. read more

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I.R.C. §280E: A Buzzkill For Those Who Keep Poor Records

By: Eli S. Noff, Partner & Mary Lundstedt

The recent Tax Court's Alterman v. Commissioner[1] decision is a lesson in Accounting 101 for Cannabisseurs. Well, technically it's a valuable lesson about record-keeping to all taxpayers who are subject to Internal Revenue Code (I.R.C.) §280E-but with the currently high audit rates for the marijuana industry, it's particularly significant for taxpayers currently in that business. read more

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Virtual and Economic Contacts Establish Nexus for Sales Tax

By: Eli Noff, Partner & Mary Lundstedt

On June 21, 2018, the Supreme Court delivered its highly anticipated decision in South Dakota v. Wayfair, Inc., et al.[1] The 5-4 decision discards the antiquated "physical presence rule" - a rule which has allowed retailers lacking a physical presence in a state to avoid any obligation to collect and remit sales taxes. Significantly, the Court overruled the long-standing interpretation of the Commerce Clause, finding that "the physical presence rule of Quill is unsound and incorrect,"[2] and that virtual and economic contacts may indeed satisfy the necessary substantial nexus requirement. read more

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Howeycoin - Too Good to be True

By Mary Lundstedt

"If you’ve ever been tempted to buy into a hot investment opportunity linked with luxury travel, the Securities and Exchange Commission has a deal for you." Sound too good to be true? It is. This announcement was made in the May 16, 2018 U.S. Securities and Exchange Commission (SEC) press release which was issued to explain the SEC’s latest educational tool related to virtual currencies. read more

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IRS Responds to States' Attempts to Circumvent SALT Cap

By Mary Lundstedt

On May 23, 2018, the IRS issued Notice 2018-54,[1] making it abundantly clear that when it comes to state efforts to circumvent the recently enacted state and local tax (SALT) deductions cap, "taxpayers should be mindful that federal law controls the proper characterization of payments for federal income tax purposes." read more

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District Court Maintains $100,000 Regulatory Cap For Willful FBAR Violations

By Eli Noff, Partner & Mary Lundstedt, Esq.

On May 16, 2018, in United States v. Colliot,[1] the District Court for the Western District of Texas held that the Internal Revenue Service (IRS) is precluded from assessing a willful Report of Foreign Bank and Financial Accounts (FBAR) penalty exceeding the $100,000 limit provided in Federal Regulation (Reg.) §1010.820. The decision is a victory for taxpayers—forcing the government to either appeal the decision or promulgate new regulations. read more

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The IRS is Receiving Thousands of Coinbase Users' Information

By Mary Lundstedt , Esq.

In November of 2017, Coinbase, Inc. ("Coinbase"), a company that facilitates digital currency transactions, was ordered to comply with an IRS summons demanding specific Coinbase client identifying information and transaction data for Coinbase accounts "with at least the equivalent of $20,000 in any one transactions type" in any year during the period of 2013-2015.[1] Approximately 14,000 Coinbase clients will be affected. The federal district court ruled that the summons, as narrowed in its decision, "serves the IRS's legitimate purpose of investigating Coinbase account holders who may not have paid federal taxes on their virtual currency profits." read more

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