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Welcome to TaxBlawg, a blog resource from Chamberlain Hrdlicka for news and analysis of current legal issues facing tax practitioners. Although blawg.com identifies nearly 1,400 active “blawgs,” including 20+ blawgs related to taxation and estate planning, the needs of tax professionals have received surprisingly little attention.
Tax practitioners have previously lacked a dedicated resource to call their own. For those intrepid souls, we offer TaxBlawg, a forum of tax talk for tax pros.
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In a high profile summons enforcement case brought by the Internal Revenue Service against Coinbase, Inc. (United States v. Coinbase Inc., No. 3:17-cv-01431 (N.D. Cal. 2017)), a virtual currency exchange for traders of popular digital cryptocurrencies like Bitcoin, Ethereum and Litecoin, the Internal Revenue Service sought the production by Coinbase of all of its customer records involving Bitcoin transactions from 2013 through 2015. The number of customers potentially susceptible to such a broad summons request was estimated at just under 500,000.
The U.S ...
During a course that I taught about tax treaties at last week’s TEI Houston Tax School, one audience member asked whether the exchange-of-information provisions of U.S. tax treaties apply not only to the federal government but also to state and local governments. I had to confess that I did not know the answer of the top of my head. However, I took a quick look at the question later in the week.
By way of background, in each income tax treaty with foreign jurisdictions, the United States negotiates an “exchange of information and administrative assistance” provision. This ...
As noted by Janet Novack at forbes.com, Judge England of the District Court for the Eastern District of California last week issued an order permitting the IRS to serve a "John Doe" summons on the California State Board of Equalization. The summons seeks the names of residents who transferred property to relatives for little or no considerations. The IRS hopes that the information it receives will identify individuals who should have, but did not, file Forms 709 - Gift Tax Returns.
According to Ms. Novack's post, the IRS' efforts involving information obtained from other states has ...
As discussed in a story in this morning's Tax Notes, the IRS intends to begin requesting electronic files as part of taxpayer examinations so that it can analyze the "metadata" contained in those files. Metadata, sometimes referred to as "data about data," generally shows information about a computer file, such as its editing history. The IRS claims that such information "may be relevant" to taxpayer examinations because the information "may support or undermine the credibility of the records offered to substantiate the accuracy of the [taxpayer's] return." See Chief Counsel ...