The Senate has confirmed the reappointment of three United States Tax Court judges. Tax Court Judges Maurice Foley, Joseph Gale, and Juan Vasquez have been reappointed for a second 15 year term.
Category Archives: Tax News
Ronald Buch nominated to U.S. Tax Court
Offshore Account Disclosure (OVDI) Deadline Extended Due to Hurricane Irene [Updated]
On Friday, in anticipation of the impact of Hurricane Irene, the IRS announced that it would extend the deadline for offshore voluntary disclosure initiative (OVDI) requests from August 31, 2011 until September 9, 2011. Taxpayers considering the OVDI program and who wish to take advantage of the extended due date for filing should take note that they are required to send two separate requests to two different IRS offices as noted below.
[Update 8/29/11] – The IRS clarifies that the September 9, 2011 extension also applies to taxpayers filing FBARs pursuant to FAQs 17 and 18.
Taxpayers with undisclosed offshore accounts who have yet to submit a request to participate in the program (and the necessary supporting documentation) now have until September 9, 2011 to:
- Send identifying information to the Criminal Investigation office. The required identifying information is name, address, date of birth, and social security number. Voluntary filers are also asked to send as much of the other information requested in the Offshore Voluntary Disclosures Letter as possible. Requirements of the OVDI Letter can be found here. This information must be sent to:
Offshore Voluntary Disclosure Coordinator
600 Arch Street, Room 6404
Philadelphia, PA 19106.
- Send a request for a 90-day extension for submitting the complete voluntary disclosure package of information to the Austin campus. Information about the complete OVDI disclosure packet can be found here. This request must be sent to:
Internal Revenue Service
3651 S. I H 35 Stop 4301 AUSC
Austin, TX 78741
ATTN: 2011 Offshore Voluntary Disclosure Initiative
Is the Carried Interest Tax Preference in Jeopardy?
A recent Wall Street Journal report by Laura Sanders suggests that the tax treatment of carried interest may be in jeopardy based on the Tax Court’s decision in Dagres v. Commissioner.
Read the Wall Street Journal article here:
“Carried Interest in the Crosshairs”
Read the opinion in our original post about Dagres.
What does Mayo Foundation mean for Tax Litigation?
The Supreme Court’s decision in Mayo Foundation will have a lasting impact. Chevron deference is now the standard. One scholar asks whether that is always the case.
What to do about regulations that appear to be promulgated in order to affect the outcome of a pending case? Does Chevron deference still apply? Does another standard apply? Should another standard apply?
Prof. Lederman of the Univeristy of Indiana at Bloomington will present “Hold the Mayo: What Respect Should Courts Accord Tax Regulations and Rulings Issued During Litigation?” at the University of Florida Faculty Colloquia Series.
Please visit Tax Prof Blog for an abstract.