by Lynam Knott | Apr 11, 2013 | Administration of Whistleblower Claims, Award Determinations, Guidance, IRS Whistleblower Office
A congratulations and a thank you to Erica Brady, who yesterday spoke on behalf of The Ferraro Law Firm’s clients at the public hearing on the Proposed Treasury Regulations that outline how the IRS will interpret section 7623. Erica joined other...
by Lynam Knott | Mar 26, 2013 | Aggressive Tax Positions, Offshore Assets, Taxpayer Underpayment, Uncertain Tax Positions
I saw an interesting article today by the President and Publisher of Tax Analysts in which he drew attention to the role of tax professionals in the growing crisis over reduced corporate tax receipts in a time of record corporate profits. He focused his...
by Lynam Knott | Mar 13, 2013 | Award Determinations, IRS Whistleblower Office, Judicial Review
The IRS has spent much time ensuring that they would not be whipsawed by paying an award on proceeds that is ultimately refunded to the taxpayer, but apparently, little consideration has been given to what happens when the IRS whipsaws a whistleblower using their...
by Lynam Knott | Mar 5, 2013 | Award Determinations
On March 4, the IRS announced through a two-paragraph statement posted to its website, that under the automatic sequester cuts, any section 7623 whistleblower awards paid between March 1, 2013, and September 30, 2013, will be reduced by a “sequestration...
by Lynam Knott | Feb 21, 2013 | Guidance
Earlier this week we filed our comments to Prop. Treas. Reg. sections 301.6103(h)(4)-1, 301.7623-1; 301.7623-2, 301.7623-3, and 301.7623-4 with the Treasury Department. In summary, our specific comments, organized by their corresponding section of the Proposed...
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