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.
The Wall Street Journal's Tax Blog gives “tips and advice for filers,” and Paul Caron’s legendary TaxProf Blog is an excellent clearinghouse for academic and policy-oriented news. Yet, tax practitioners still lack 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
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 involving Bitcoin transactions from 2013 through 2015. The number of customers potentially susceptible to such a broad summons request was estimated at just under 500,000.
The U.S ...
Five days ago, this would have seemed like just another April Fools' Day joke, but it is apparently quite real. Via the Washington Times, an excerpt:
There's at least one government function some taxpayers might not miss in a government shutdown: IRS tax audits.
A senior administration official, briefing reporters on potential effects of a shutdown, said "the performance of tax audits will be shut down or suspended for this period."
Overall, the official said he expects about 800,000 government employees to be furloughed if Congress and the president aren't able to agree on spending ...
As a follow up to my colleague George Connelly's earlier post concerning the IRS's recently announced "Global High Wealth" Industry Group, I offer some further thoughts on what the IRS is attempting to do with this new group focusing on wealthy individuals. The IRS recently announced that the group has issued its first batch of audit letters and the audits of wealthy individuals will soon commence.
The IRS has created the group in the LMSB division, which generally handles audits of the largest corporations under a "team" audit concept. A team audit means that the IRS assigns several agents to the case, including, where appropriate, specialists in areas like international taxes, financial products, and employment taxes, as well as engineers and economists.
The IRS is concerned with very wealthy individuals who own multiple entities using complicated structures to avoid U.S. federal income taxes. The individuals may be operating foreign businesses or may have foreign investments through foreign trusts, partnerships, or corporations.