Opportunity Virginia Program Officially Launched

In 2017, Congress passed the Tax Cuts and Jobs Act,[1] which included the Opportunity Zone tax incentives designed to spur investments in low-income census tracts. On October 22, 2019, Virginia Governor Ralph Northam announced the official launch of Opportunity Virginia.[2] Opportunity Virginia’s mission is specifically:

to encourage and enable investments with positive impacts in communities by ensuring fair and equitable access to resources and facilitating productive connections ...


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...