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Tax Liability › Tax Avoidance › Tax Planning

Gerald Nowotny - Law Office of Gerald R....

Still the One! – The Use of Private Placement Life Insurance in Tax Planning for Trial Attorneys with Contingency Fee Income

Gerald Nowotny - Law Office of Gerald R.... on

In the Soundtrack of Our Lives, one of the songs that I still get to hear from time to time on Sirius XM, is “Still the One” which was recorded and released by the band Orleans in 1976. I was in the tenth grade just to be...more

Latham & Watkins LLP

Restructuring Plans and Tax Liabilities A More Assertive HMRC

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Companies must approach HMRC with suitable care when proposing a restructuring plan, mindful of lessons learned from recent case law. Ever since unpaid taxes due to HMRC were “crammed down” pursuant to a restructuring plan...more

Polsinelli

Conservation Easements: Palpable Fraud or Honest Mistakes? A Federal Jury Returns a Split Verdict

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On September 22, 2023 a federal jury convicted two promoters, CPA Jack Fisher and attorney James Sinnott, in the Department of Justice’s (“DOJ”) first criminal trial over allegedly abusive syndicated conservation easements...more

Freeman Law

Fraud Penalty Affirmed: In Not-So-Chic Fashion, the Ninth Circuit Upholds Fraud Penalties in Chico

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In Chico v. Commissioner, the taxpayers challenged the Tax Court’s assessment of a fraud penalty. The Tax Court had imposed civil fraud penalties against the married taxpayers, finding clear-and-convincing evidence of fraud...more

Bennett Jones LLP

Income Tax Update from the Supreme Court of Canada: The GAAR Does Not Apply to Treaty Shopping

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The Duke of Westminster Principle Still Lives On for Tax Planning - On November 26, 2021, the Supreme Court of Canada released its decision and reasons in Her Majesty the Queen and Alta Energy Luxembourg S.A.R.L., 2021 SCC...more

Freeman Law

Section 6700 Penalties – False or Fraudulent Statements

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Promoting abusive tax shelters. Taxpayers and tax return preparers should be aware of the various penalties that exist and can be assessed for certain actions (or nonactions). One such action includes promoting an abusive tax...more

Freeman Law

Qualified Amended Returns: How to Avoid Tax Penalties

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A “qualified amended return” is an amended tax return that, if properly filed before a taxpayer is “on the IRS’s radar,” protects a taxpayer against accuracy-related penalties—in layman’s terms, it is a get-out-of-jail-free...more

Rivkin Radler LLP

Thinking About ‘Avoiding’ NY Tax Increases? Then Think About The False Claims Act

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According to Justice Learned Hand, “Any one may so arrange his affairs that his taxes shall be as low as possible; he is not bound to choose that pattern which will best pay the Treasury; there is not even a patriotic duty to...more

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