by Lynam Knott | Feb 21, 2011 | Offshore Assets, Voluntary Disclosure Initiative
The IRS has announced its second special voluntary disclosure initiative for U.S. taxpayers with unreported foreign bank accounts. The new program, called the 2011 Offshore Voluntary Disclosure Initiative (OVDI) is not to be confused with the first disclosure...
by Lynam Knott | Feb 15, 2011 | Tax Whistleblower Racing Team
In the past some people have asked me “What does a tax lawyer do for fun, sharpen pencils?” While I enjoy grinding lead as much as the next person, I prefer burning rubber. As the driver for the CodeBlue/Tax-Whistleblower.com Racing Team, I...
by Lynam Knott | Feb 1, 2011 | Aggressive Tax Positions, Uncertain Tax Positions
A recent article in the NY Times caught our attention because it describes how many of the S&P 500 companies are drastically reducing their US taxes. Columnist David Leonhardt also discusses this issue in the Economix blog. The story relates to the low...
by Lynam Knott | Jan 28, 2011 | Award Determinations, Judicial Review
One of the biggest improvements the 2006 amendments made to the IRS Whistleblower program was providing the right to appeal an award determination for claims that meet the requirements for the enhanced award provisions, mainly that the amount in controversy is more...
by Lynam Knott | Jan 18, 2011 | IRS Whistleblower Office
On December 13, 2010, the IRS Whistleblower Office published its annual report to Congress for fiscal year 2009 (PDF). The report revealed that the IRS Whistleblower Office has received a steady stream of information about multi-million dollar tax underpayments over...
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