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Foreign Government Receives a “FATCA Christmas Gift” from IRS: 1 Gigabyte of...
Originally published by impuestosypatrick. The last post discussed how the director of the Mexican tax administration was critical of the U.S. federal government for not providing FATCA information on...
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Trade Preferences Extension Act of 2015 …
Originally published by Thompson & Knight LLP. Posted by Mary McNulty and Lee Meyercord The Trade Preferences Extensions Act of 2015 (the “Act”) (available here) dramatically increased...
View ArticleTo Group or Not to Group Under the Guidelines
Originally published by Jack Townsend. United States v. Doxie, 2016 U.S. App. LEXIS 5 (11th Cir. 2016), here, that deals with the Sentencing Guidelines’ concept of grouping. First, the facts relevant...
View ArticleFifth Circuit Reverses Sentencing Court on Conditions of Restitution and...
Originally published by Jack Townsend. In United States v. Thody, 2016 U.S. App. LEXIS 298 (5th Cir. 2016) (unpublished), here, the defendant (Thody) was convicted of “multiple counts of tax evasion.”...
View ArticleShould Proof of No Tax Evaded Be Admissible as Defense …
Originally published by Jack Townsend. Tax evasion, § 7201, here, requires proof of a tax evaded as an element of the crime. Other prominent tax crimes do not require proof of tax evaded as an element...
View ArticleMore on the U.S. as the World’s Tax Haven
Originally published by Jack Townsend. On the theme of U.S. laws offering tax haven opportunities for foreign persons, Jesse Drucker reports on one instance of a Swiss category 2 bank, Rothschild &...
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Increased FIRPTA Withholding Rate and Other PATH Act Changes Go Into Effect
Originally published by Thompson & Knight LLP. Posted by Kathleen Gerber, John Cohn, and Todd Lowther On December 18, 2015, President Barack Obama signed the Protecting Americans from Tax Hikes...
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New Developments in the Determination of the Texas Franchise Tax Liability
Originally published by John Bradford. The Texas Franchise Tax is imposed on taxable entities that do business in Texas or that are chartered or organized in the state. Taxpayers subject to the Texas...
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President Obama Signs Consolidated Appropriations Act
Originally published by Guest Blogger. On December 18, 2015, President Barack Obama signed into law the Consolidated Appropriations Act, 2016 (H.R. 2029) (the Act). The Act includes multi-year...
View ArticleGood Discussion of the Burden of Proof When the Trier of Fact …
Originally published by Jack Townsend. A case decided yesterday by the Fifth Circuit has a pretty good discussion on the effect of § 7491‘s shift of the burden of proof when the Tax Court may have...
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