On April 16, 2019 the IRS Large Business and International division (LB&I) announced the approval of three additional compliance...

<p>This paper was presented to the IRS in Washington, D.C. at the California Lawyers Association, Taxation Section, 2019 Washington D.C. Delegation. The proposal was prepared by Steven L. Walker and Adria Price, members of the Tax Procedure &amp; Litigation Committee.</p>

<p>On April 16, 2019 the IRS Large Business and International division (LB&amp;I) announced the approval of three additional compliance campaigns. Two of these campaigns, the Captive Services Provider Campaign and the Loose Filed Forms 5471 Campaign, are of importance to our clients and are explained in further detail below. Loose Filed Forms 5471 Form 5471,&#8230; </p> <div class="clear"></div> <p><a href="https://walk-law.com/irs-announces-new-campaign-form-5471/" class="ex

<p>On November 20, 2018, the IRS issued a Memorandum addressing the process for all voluntary disclosures (both domestic and foreign) following the close of the Offshore Voluntary Disclosure Program on September 28, 2018.  In March 2019, the IRS released new Form 14457, Voluntary Disclosure Practice Preclearance Request and Application.  The updated guidance and new form&#8230; </p> <div class="clear"></div> <p><a href="https://walk-law.com/irs-updated-voluntary-disclosure-pr

<p>Has a client received a letter from the IRS asking to schedule an appointment to examine the client&#8217;s compliance with the requirement to file FinCEN Report 114, Report of Foreign Bank and Financial Accounts (FBAR)? Although an FBAR examination is not an income tax examination, the client may be liable for penalties for failure to&#8230; </p> <div class="clear"></div> <p><a href="https://walk-law.com/is-your-client-the-subject-of-an-fbar-examination/" class="excerpt-r

<p>Steven L. Walker recently attended the 34th Annual National Institute on Criminal Tax Fraud and the Seventh Annual National Institute on Tax Controversy, sponsored by the ABA Section of Taxation and ABA Criminal Justice Section.  The conference, which is held in Las Vegas, Nevada each year, provided an excellent update on IRS enforcement efforts and&#8230; </p> <div class="clear"></div> <p><a href="https://walk-law.com/recent-developments-irs-enforcement-priories/" class="

<p>Where are We Going in 2019? I recently returned from the 34th Annual National Institute on Criminal Tax Fraud and the Seventh Annual National Institute on Tax Controversy, sponsored by the ABA Section of Taxation and ABA Criminal Justice Section.  The conference provides an excellent update on IRS enforcement efforts and priorities and insight into&#8230; </p> <div class="clear"></div> <p><a href="https://walk-law.com/recent-developments-top-irs-enforcement-priorities/" cl

<p>Recently, in a closely watched case, the California Superior Court in San Francisco rejected the Franchise Tax Board’s long-standing approach to the taxation of trusts.  The court determined that all income, including California-source income, is subject to the apportionment formula set forth in California Revenue &amp; Taxation Code Section 17743, et seq.</p>