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Voluntary disclosure and IRS attacks on offshore credit cards.
April 1, 2003... The Internal Revenue Service is greatly concerned about the foreign activities of U.S. individuals and corporate taxpayers. Hence, it is not surprising that the IRS has been aggressively attempting to uncover tax-avoidance plans involving the...
Preliminary procedures during an audit examination of the worker classification issue.
April 1, 2003... Preliminary Procedures During an Audit Examination of the Worker Classification Issue
The audit examination of whether workers constitute employees or independent contractors will proceed at a certain pace. In so doing, there are a few...
Section 304 redemption treated as sale or exchange under firm-and-fixed standard.
April 1, 2003... Section 304 Redemption Treated as Sale or Exchange Under Firm-and-Fixed Standard
The Tax Court recently considered whether cross-chain section 304 stock sales between members of a consolidated group must be integrated with the subsequent...