Archive for Tax Risk Management

If Unmeasured, Is It Really Success? An Introduction To Measuring Tax Function Value


An introduction to measuring tax function value

One of the challenging topics in tax management is how to measure the success of the function.  Some of the most seasoned tax leaders of the largest organizations will say the main measure of success is the “no surprises” rule; If corporate management is never surprised by a tax result, the tax department and its leaders are deemed successful.  Although the sentiment is understandable, this highly subjective notion is hardly something that can be Read more

Creating Tomorrow’s Tax Value With Today’s Successes


An introduction to sustainable tax value

Shortly after I was appointed chief tax officer (CTO) of a public company, a local attorney sent me a small congratulatory gift.  It was book called 101 Corporate Tax Loopholes.  That did not sit very well with me.  While “loopholes” may be legally defensible, it just sounds bad.  So, in typical smart-alecky Read more

U.S FinCEN Will Track Secret Buyers of Luxury Real Estate in Manhattan and Miami

Ronald Marini

The Financial Crimes Enforcement Network (FinCEN) today January 13, 2016 issued a Geographic Targeting Orders (GTO) that will temporarily require certain U.S. title insurance companies to identify the natural persons behind companies used to pay “all cash” for high-end residential real estate in the Borough of Manhattan in New York City, New York, and Miami-Dade County, Florida.

FinCEN is concerned that all-cash purchases – i.e., those without bank financing – may be conducted by individuals attempting to hide their assets and identity by purchasing residential properties through limited liability companies or other opaque structures. To enhance availability of information pertinent to mitigating this potential money laundering vulnerability, FinCEN will require certain title insurance companies to identify and report the true “beneficial owner” behind a legal entity involved in certain high-end residential real estate transactions in Manhattan and Miami-Dade County.
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Tax Preparation Questions To Ask Yourself

Milton Boothe

When you leave your tax preparer’s office each year, there are two very important questions you should probably be asking yourself.

Question #1:

How secure is your personal information after you leave it with your tax preparer? Probably not very secure! Do they leave your paperwork lying about the place, accessible to all, after they have completed your taxes? Are their computers adequately protected by firewalls and effective anti-virus software? Is there adequate background checks done on their employees, who obviously will have unlimited access to your sensitive personal information? The honest truth is that you really don’t know.

Also, you should be concerned about hackers. These criminals have been successful in hacking into supposedly very secure government computer systems; the Office of Personnel Management, and even the IRS itself come to mind immediately. These people know that they will have access to a treasure trove of personal information if they were to hack into the computers of H&R Block, Liberty Tax, or any CPA or other tax preparation office. So what is to stop them from hacking into your tax preparer’s computer, which obviously will be a lot less protected than the government’s computers? Read more

§ 165(e) Loss Claimed On Theft of Money/Investment

Daniel Erasmus3

I am pleased to announce another successful settlement for a client.

IRS denied a big deduction based on a Ponzi type investment stating the taxpayer had claimed the deduction in the wrong year. It must be the year it came to his attention and only up to the amount lost especially if there is a chance to recover some in the future.

The matter was set to go to trial in Miami, but I reached agreement he would deduct 80% in the year the loss was claimed and 20% in the year in which there was certainty he had lost everything. That year is still open to claim the 20%. Protective filings were made by his accountant.

The turning point was making clear the evidence we would present to back-up the client’s claim. This convinced the Read more

Meet Dr. Daniel Erasmus – Managing Partner, Transfer Pricing Expert, Tax Risk Management

Daniel Erasmus2

TaxConnections would like to introduce Dr. Daniel Erasmus, Managing Partner and Transfer Pricing Expert at Tax Risk Management.

An Enrolled Agent and a member of the US Tax Court Bar in all 50 states, his experience as international attorney has led him and his team to represent clients all over the world in tax controversies, especially transfer pricing in Africa.

These clients include:

Various US clients;
A major German car manufacturing company;
The 2nd largest beer brewer in the world; Read more

U.S. Multinationals Being Pursued By African Revenue Authorities With Large Tax Assessments

Daniel Erasmus
U.S. Multinationals Being Pursued By African Revenue Authorities With Large Tax Assessments


Learn what Dr. Daniel Erasmus/Transfer Pricing Expert, Tax Risk Management and International Tax Attorney will be discussing at the upcoming TaxConnections Internet Tax Summit.  Listen to his transfer pricing example about reducing significant tax exposure for Multinationals in this video.



Join Us Online-Internet Tax Summit





South African Tax Man’s Message To HSBC Account Holders

Close up of 20 50 100 South African currency the Rand isolated on white background

The South African Revenue Service (SARS) has announced an amnesty of sort – a threat and upfront warnings: we do know about you, best you come forward before we make the tax audit into your affairs known.

On July 9th, 2015, SARS issued a press release, which can be read in more detail on: – – – South-Africans-with-accounts-and-investments-in-foreign-tax-jurisdictions.aspx

The International Consortium of Investigative Journalists (ICIJ), based information obtained by French newspaper Le Monde, ranked South Africa number 31 among the countries with the largest amount of dollars ($2.3blion) in the so-called leaked Swiss Read more

Government Expands Forfeiture Program

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In 1984, George Orwell’s novel about a dystopian near-future society, Oceania was constantly at war with one of its geopolitical rivals. The grandfatherly yet sinister O’Brien later admitted that victory over Eurasia or Eastasia was not the war’s objective – the ongoing conflict was simply an excuse for the totalitarian government to intervene in peoples’ affairs.

The United States is in the midst of several wars, many of which are against rather amorphous opponents. Case in point: the war on drugs. It’s not exactly like Oceania’s war against Eurasia/Eastasia, but there are some common elements. Both conflicts are seemingly endless, and both have political overtones. Perhaps most significantly, in both conflicts, bystanders are caught in the crossfire. Read more

Australian Tax Office BEPS “Progress Report”

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In a speech last week ATO’s Mark Konza, Deputy Commissioner – International, gave an insight into the ATO’s activities in responding to a number of the OECD’s post Cairns G20 Minister’s Conference BEPS Action Plan items.

Deputy Commissioner Konza put particular emphasis on the ATO’s strategy in connection with “Action Item 1: address the tax challenges of the digital economy”. Commenting on the ATO’s work on this aspect he said-

“The broader digital economy is also being addressed through our four-year dedicated compliance program to address International Structuring and Profit Shifting (ISAPS). Tax and law professionals from external firms have been recruited into the ATO to help Read more

Has Uncle Sam Gone Mad? FATCA, BRS, AEOI And Other Strange Words Pouring Into South Africa

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In South Africa, the South African Revenue Service (SARS the local equivalent of the IRS) has just issued a draft public notice for comment and it refers to strange new terminology, not always correctly understood by the non-American resident.

Most US expats and failed SA expats returning from the USA with a green card in the back pocket, are all facing being caught red handed. Yes, for many years SARS was not the best of gossip queen in the OECD. The cam the Krok case and SARS received some interesting info from the ATO. Not only did SARS wake up to the word FOUNDATION they also saw the benefit of acting in “cohort” with another tax authority.

Suddenly the effort to make FATCA happen for FFI’s in South Africa, became an interesting Read more

Timely Filed Petition? Miami Tax Court

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Miami Tax Court Report Back

Judge Ronald L. Buch – timely filed petition?

IRS filed a motion to dismiss for lack of jurisdiction. The USPS click and ship process was used by a representative of the taxpayer. She printed the label with payment from the USPS site at 11:48 pm. Petition had to be timely filed by 12 – 12 minutes later. IRS averred that it was impossible for her to print, stick and deliver the petition to the USPS in Jupiter, FL within 12 minutes as the petitioner’s address was about 20 minutes from the USPS. What IRS did not know, as testified, was that the petitioner had moved, and lived 3 minutes from the USPS. This evidence was led in court. So it was possible to timely mail Read more