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Archive for January 22, 2021

Tax Court Denies Award In Recent Whistleblower Tax Case

Tax Court Denies Award In Recent Whistleblower Tax Case

Kennedy v. Comm’r, T.C. Memo. 2021-3 | January 12, 2021 | Copeland, E. | Dkt. No. 5687-17W

Short Summary:  Petitioner appealed, pursuant to § 7623(b)(4), three determinations of the Whistleblower Office (WBO) of the Internal Revenue Service (IRS) that declined to make awards to him.  Petitioner filed a single whistleblower claim, but the WBO split it into three distinct claims. Petitioner’s whistleblower claim alleged that three taxpayers and related subsidiaries owed $150,103,245 in unpaid excise taxes, penalties, and interest. The IRS processed the claims, and it took no action against two of the taxpayers, and no change resulted from the examination of the third taxpayer.  Petitioner challenged the WBO’s determinations. The Tax Court held that the WBO did not abuse its discretion in declining any awards to Petitioner.

Key Issue:  Whether the WBO abused its discretion in declining to award the Petitioner any amount under his whistleblower claims when it took no action against two taxpayers and issued no changes after the examination of the third taxpayer.

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Ask Ed Questions & Answers: A Nationally Recognized Financial Planning Expert On How To Seek Tax Free Income

Ask Ed Questions & Answers: A Nationally Recognized Financial Planning Expert On How To Seek Tax Free Income

Taxes may be going up – again – in the near future.
(Free Gift At Bottom Of This Post For First 500 Requests)

Question:  Do Tax-free municipal bonds have a place in your portfolio?

Answer: Generally, if your income tax rate, after deductions, is 25% or higher, you may be good candidate for tax-free bonds.

Question: What are my choices, when seeking tax-free income?

Answer: You have several choices:

DIY. This involves buying bonds from brokerage firms and doing all the research and monitoring for both credit quality and prices. Transparency can be challenging and markups are not disclosed, so you may significantly overpay. But at least there are no management fees and you can assemble a portfolio of individual bonds, each with a stated final maturity.

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Guidance For Expatriates: Determining Net Worth For 877A Exit Tax Purposes – IRS Notice 97-19

Guidance For Expatriates: Determining Net Worth For 877A Exit Tax Purposes - IRS Notice 97-19

We genuinely appreciate TaxConnections members for the important role they play in educating tax professionals and taxpayers on rules and regulations they surface in the IRS tax code. These treasures finds are very helpful to so many and in this case John Richardson identifies Guidance For Expatriate Under Section 877 2501 210 and
6039F known as IRS Notice 97-19. If you are an expatriate, this is an important IRS Notice for you to read.

Guidance For Expatriate Under Section 877 2501 210 and
6039F (Notice 97-19)

PURPOSE

The Health Insurance Portability and Accountability Act of 1996
(the “Act”) recently amended sections 877, 2107 and 2501 of the Internal Revenue Code (the “Code”), and added new information reporting requirements under Section 6039F. This notice provides guidance regarding certain federal tax consequences under these sections and section 7701(b)(10) for certain individuals who lose U.S. citizenship, cease to be taxed as U.S. lawful permanent residents, or are otherwise subject to tax in the manner provided by section 877.

This notice has eleven sections:
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Learn How Multinational Corporate Tax Executives Are Taking Control Of Transfer Pricing Remotely

TRANSPORTAL- Transfer Pricing Software

It goes without saying that the COVID-19 pandemic is the major concern of nearly all multinational enterprises (MNEs) at the moment. Radical containment measures continue to be put in place by governments around the world in efforts to slow the spread of the virus. Many of these measures center on the concept of ‘social distancing’ and have included closing businesses and organizations, cancelling events, prohibiting international and domestic travel, and quarantining cities and even regions. COVID-19 containment measures have disrupted business as usual, from manufacturing plant shutdowns to creating information inefficiencies and collaboration challenges at MNE headquarters and across global entities. These business disruptions create challenges for effectively managing transfer pricing information and workflows.
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