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William Byrnes (Texas A&M) tax & compliance articles

Posts Tagged ‘Tax Negotiation and Representation’

Gift Tax Return Disclosures—Adequate or Else

Posted by William Byrnes on October 1, 2010


A recent IRS Chief Counsel Advice addressed the importance of making adequate disclosures to the IRS when filing a gift tax return, demonstrating the dangers of a tight lip. There, a taxpayer failed to disclose the method and valuation discounts used to value gifted stock.  As a result, the taxpayer was unable to seek the protection from gift tax changes based upon the three year statute of limitations.

The statute of limitations for the IRS to question an item on a gift tax return is essentially unlimited if a gift is not “adequately disclosed” on the return, so taxes—and fees and interest—can be imposed on the inadequately disclosed gift any time after the return is filed.

For the complete analysis of this development regarding the disclosures required on a gift tax return by our Experts Robert Bloink and William Byrnes, please read the article via your AdvisorFX subscription at Gift Tax Return Disclosures—Adequate or Else?

For in-depth analysis of this topic, see Advisor’s Main Library Section 7. Gift Taxes D—Valuation For Gift Tax Purposes and from a tax perspective see Tax Facts Q 1534 What are the requirements for filing the gift tax return and paying the tax?

After reading the analysis, we invite your questions and comments by posting them below, or by calling the Panel of Experts.

Posted in Estate Tax | Tagged: , , , , , , , | Leave a Comment »

IRS Proposed FATCA Guidance Expands Offshore Compliance Initiatives

Posted by William Byrnes on September 18, 2010


The IRS released proposals for FATCA guidance on August 27, 2010, in Notice 2010-60.  The notice outlines the shape of the regulations and raises grave concerns for a wide swath of transactions that have an offshore component— from foreign investments to captives and beyond.

Today’s analysis by our Experts William Byrnes and Robert Bloink is located at AdvisorFX Journal IRS Proposed FATCA Guidance Expands Offshore Compliance Initiatives.

After reading the analysis, we invite your questions and comments by posting them below, or by calling the Panel of Experts.

Posted in Compliance, information exchange | Tagged: , , , , , , | Leave a Comment »

 
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