Recently by Brian A. Silikovitz
The Tax Relief Act Of 2010: Key Business And Individual Income Tax Provisions And Incentives
On December 17, 2010, President Obama signed into law the Tax Relief, Unemployment Insurance Reauthorization, and Job Creation Act of 2010 (the "Act"). This article briefly summarizes some of the key federal income tax provisions of the Act affecting individuals and businesses. The Act generally...
Read MoreFirst Circuit Denies Work Product Protection For Tax Accrual Workpapers
1 I.R.M. 4.10.20.2 (7/12/2004). 2 Internal Revenue Code of 1986, as amended, § 7602. 3U.S. v. Arthur Young & Co., 465 U.S. 805 (1984), rev'g 677 F2d 211 (2nd Cir. 1982), rev'g 496 F. Supp. 1152 (D.C. N.Y. 1980). 4 No. 07-2631 (1st Cir. Aug. 13, 2009) (en banc). 5 Announcement 2002...
Read More"You May Still Rely On This Advice" - What The New Circular 230 Tax Disclaimer Means For You
You may already have seen them - disclaimers on letters and emails that contain tax advice - disclaimers that say that the recipient of the advice cannot rely on the advice for the purpose of avoiding penalties. These ominous-looking disclaimers are the result of new Treasury Regulations that...
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