A recent study by the Institute on Taxation and Economic Policy details how Fortune 500 Companies are holding a record $2.6 trillion offshore, thereby avoiding $767 billion in U.S. taxes.  While we believe much of this amount is the result of lawful tax planning on the companies’ international operations and the use of tax

Today’s CFO Journal reported that a warning from the Public Company Accounting Oversight Board (“PCAOB”) late last year has resulted in much more stringent external audits being conducted by auditors of public companies.  PCAOB has been auditing the auditors to make sure public companies’ financials are not being rubber stamped.  Increased audit scrutiny can be

Tax shelters are an on-going battle for the IRS and the Department of Justice with large amounts of money at stake for the government, the taxpayer, and possibly for a knowledgeable whistleblower.  Tax shelter cases involve schemes that attempt to manipulate internal revenue laws in order to reduce participants tax liability and are typically marketed

Thumbnail image for MartySullivan1-800x531.jpgKudos to Martin Sullivan, Chief Economist and Contributing Editor at Tax Analysts who had a nice piece in the Washington Post published about him over the weekend.  I’ve always admired Marty’s ability to cut through the political BS and revenue scoring to see the true cost and impact of our tax laws and proposed tax

I saw an interesting article today by the President and Publisher of Tax Analysts in which he drew attention to the role of tax professionals in the growing crisis over reduced corporate tax receipts in a time of record corporate profits. He focused his audience’s attention on a recently released study by The Organisation

Joseph A. Insinga, retired Rabobank Finance Specialist, filed a petition with the Tax Court arguing that the IRS’s continued refusal to issue a formal determination constitutes a de facto rejection of his claim and appeals this de facto rejection.  This filing details five years of interaction between Mr. Insinga and the IRS and has brought

In the tax world, unlike Hollywood, we really don’t get that many juicy stories.  However, when the “stars” embarrass themselves with their tax troubles, we are provided relief from yet another story about, for example, the material participation regulations’ conjunctive test for determining whether an interest is treated as a limited partner interest for purposes

The IRS estimates that the gross tax gap for 2006 is $450 billion, or 17 percent of taxes.  The gross tax gap is the amount of the true tax liability faced by taxpayers that is not paid on time.  After its enforcement efforts, the IRS estimates that the net tax gap is $385 billion,

Bloomberg News/Businessweek’s Jesse Drucker makes an astute observation about how billionaires either delay or escape income taxes in his article “U.S. Billionaires Avoid Reporting Cash to IRS.”  The article describes how several people on the Forbes 400 list have used sophisticated and complex transactions to characterize the cash that they receive from the sale