Untimely CDP Arguments Worth Consideration

By Eli S. Noff, Esq., CPA, Partner Mary Lundstedt, Esq. The taxpayer in Berkun v. Commissioner1 ultimately raised two collection due process arguments too late for consideration on appeal, but the Eleventh Circuit apparently found them worthy enough to highlight in a published opinion. Although the Eleventh Circuit uses a popular Seinfeld reference to describe its own non-substantive ruling in Berkun as potentially appearing to be an opinion "about nothing,"2 the opinion puts practitio...

Coming Out of the Dark of International Tax Avoidance

Failing to Pay Taxes
By: Eli S. Noff, Partner and Peter Palsen Jakarta, Indonesia (1990) - The aroma of my strong Java coffee blended with the smell of the dark teak paneling of the conference room of my client's office. I glanced at my U.S.-citizen client and then back to the two bankers who had traveled to Indonesia to promote an investment in an offshore fund. Before the meeting, I had made my client aware that the U.S. Congress had only a few years earlier enacted a punitive rule to discourage U.S. tax res...

Gifts and Inheritance from Abroad: How Do U.S Tax Rules Apply?

Inheritance Tax from Abroad
When it comes to receiving gifts and inheritances from individuals living abroad, there are specific rules in the tax code that apply. The rules depend on whether you receive the gifts from a U.S. citizen or resident alien or someone who is a citizen of another country. If you receive a gift or inheritance from another U.S. citizen or resident alien living in another country, then U.S. gift tax and inheritance tax laws will apply to your situation.

What Are the Reporting Requirements?