DOJ Tax Division is Interested in Whistleblower Information, but Risks of Disclosure Should Be Discussed with Counsel Prior to Disclosure

By | Tax Whistleblower Report | December 9, 2016

Caroline Ciraolo, Principle Deputy Assistant Attorney General, Department of Justice Tax Division, made clear the importance of whistleblower counsel while speaking at the American Bar Association’s National Institute on Criminal Tax Fraud and Institute on Tax Controversy in Las Vegas.

Tweet Like LinkedIn LinkedIn Google Plus

Update On Proposed Tax Regulations Affecting Availability of Valuation Discounts to Family Business Owners

Update On Proposed Tax Regulations Affecting Availability of Valuation Discounts to Family Business Owners

In September, we posted a blog discussing the Treasury Department’s issuance of proposed regulations under Section 2704 of the Internal Revenue Code (sometimes referred to as the 2704 proposed regulations) that could significantly impact the valuation of interests in family-owned businesses for estate and gift tax purposes.

Tweet Like LinkedIn LinkedIn Google Plus

Proposed Regulations Address Applicable Adjustments to Stock and Stock Rights Under Code Section 305(c)

By | Tax Controversy 360 | December 8, 2016

In an apparent response to coordination questions raised by comments to proposed regulations under Code Section 871(m) (relating to certain cross-border dividend equivalent payments), the US Department of the Treasury issued proposed regulations on April 12, 2016, (the Proposed Regulations) addressing deemed distributions of stock and stock rights under Code Section 305(c).

Tweet Like LinkedIn LinkedIn Google Plus