Welcome to TaxBlawg, a blog resource from Chamberlain Hrdlicka for news and analysis of current legal issues facing tax practitioners. Although blawg.com identifies nearly 1,400 active “blawgs,” including 20+ blawgs related to taxation and estate planning, the needs of tax professionals have received surprisingly little attention.
Tax practitioners have previously lacked a dedicated resource to call their own. For those intrepid souls, we offer TaxBlawg, a forum of tax talk for tax pros.
Chamberlain Hrdlicka Blawgs
According to the Financial Times, companies around the world are preparing for the possibility of a breakup of the euro. Given the currency devaluation that would likely occur in countries coming out of the euro, these companies are preparing for the impact that such an event would have on balance sheets (e.g., asset prices) and income statements (e.g., import costs). (For additional FT coverage of the issue, see here.)
As we noted in the TaxBlawg a while back when the euro crisis was still focused primarily on Greece, a partial or complete breakup of the eurozone would give rise to a host ...
When the IRS audits a tax return involving a business, its agents invariably get involved in questions of recordkeeping and how transactions are conducted and recorded. All too often, an IRS Examiner will suggest that a taxpayer's records are not "adequate," or that in some fashion the taxpayer is not operating in "a businesslike manner." This most often occurs in situations where the taxpayer is attempting to operate a ranch and has incurred losses, or claims that shareholder advances to the company should be recognized as bona fide loans rather than an investment of capital.
Your writer has been dealing with tax disputes for over 40 years, and believes that the two most important developments for taxpayers were the passage of the 1998 IRS Restructuring and Reform Act, and the creation of the Taxpayer Advocate Service ("TAS," formerly known as the "Problem Resolution Office" and the "Ombudsman"). The Advocate created to assist taxpayers where, for lack of a better term, the system simply was not working properly, and for most of its existence has done a wonderful job.
Well, that organization's health now appears to be in peril. IRS Commissioner Shulman has ...