<p>Mr. Walker was invited to Washington D.C. by the Taxation Section, State Bar of California, to present a position paper regarding The Modification and Compromise of Restitution Orders in Criminal Tax Cases.  The paper was presented to the Internal Revenue Service, United States Treasury Department, U.S. Tax Court, and Congressional personnel.</p>

<p>During the course of an IRS investigation, the IRS has the authority to issue an administrative summons seeking records and testimony (Sec. 7602).  The IRS may summons records, whether they are in the taxpayer’s or a third party’s possession, including in the possession of the taxpayer’s business associates, acquaintances, prior employers, and even financial institutions&#8230; </p> <div class="clear"></div> <p><a href="https://walk-law.com/can-taxpayer-refuse-irs-summons/

<p>On Aug. 29, 2013, the U.S. Department of Justice (DOJ) and the Swiss Federal Department of Finance signed a joint statement aimed at resolving tax compliance issues unique to Switzerland. As part of this combined enforcement effort, the DOJ announced a new program that is intended to provide a path for Swiss banks that are&#8230; </p> <div class="clear"></div> <p><a href="https://walk-law.com/swiss-banks-send-letters-u-s-account-holders-americans-risk/" class="excerpt-read

<p>A recent revenue procedure and chief counsel notice reflect significant IRS policy and procedural changes for claims under section 6015(f). The IRS has relaxed the eligibility conditions for innocent spouse relief, and for the first time, there is now uniform law in the Tax Court. A taxpayer obtains a de novo trial, and there is&#8230; </p> <div class="clear"></div> <p><a href="https://walk-law.com/irs-changes-policy-relaxes-rules-innocent-spouse-relief/" class="excerpt-re

<p>This paper provides a framework for discussing the implementation of a voluntary disclosure program for individuals and businesses with the California Franchise Tax Board.  The Internal Revenue Service has had a voluntary disclosure program for more than half a century, and it provides a mechanism for taxpayers to get back into compliance by making a&#8230; </p> <div class="clear"></div> <p><a href="https://walk-law.com/proposed-voluntary-disclosure-program-california-fran

<p>Individuals should exercise prudence in evaluating transactions designed to generate paper losses on federal income tax returns—so-called tax shelters.  Taxpayers should focus on the value of the underlying asset reported on the return and ask whether that valuation makes sense. In an unusual move, the U.S. Tax Court recently overturned its precedent to side with&#8230; </p> <div class="clear"></div> <p><a href="https://walk-law.com/irs-will-not-let-investors-off-hook-over

<p>This article examines what can happen to an individual who fails to report foreign bank accounts on FinCEN Form 114 to the Internal Revenue Service.</p>

<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