<p>An individual living in the United States may own a retirement plan from another country. The Internal Revenue Service (&#8220;IRS&#8221;) takes the position that certain foreign retirement accounts are foreign trusts and subject to the onerous reporting requirements of section 6048 of the Internal Revenue Code of 1986, as amended (the &#8220;Code&#8221;) and the penalties&#8230; </p> <div class="clear"></div> <p><a href="https://walk-law.com/simplified-procedure-allow-lat

<p>Mr. Walker was invited to Washington D.C. by the Taxation Section, State Bar of California, to present a position paper regarding practitioners’ views of the United States Tax Court.  The paper was presented during a luncheon meeting to Judges of the Tax Court.</p>

<p>&nbsp; CPAs often find themselves representing individuals and businesses being audited by the IRS, as well as negotiating settlement of tax disputes in cases pending before the IRS Office of Appeals. Clients rely on their CPAs, even after a Tax Court petition is filed, to provide tax advice with respect to litigating positions being taken&#8230; </p> <div class="clear"></div> <p><a href="https://walk-law.com/new-tax-court-rule-may-change-way-irs-pursues-depositions-califo

<p>The issue is the proper tax treatment of a financial guarantee from a parent company to a wholly-owned subsidiary for Federal income tax purposes. The Service issued Treas. Reg. § 1.482-9 to provide guidance with respect to controlled services transactions, but the regulations carve-out financial guarantees from the regulations’ applicability.3 This raises the question as&#8230; </p> <div class="clear"></div> <p><a href="https://walk-law.com/application-section-482-transfe