Firm Insights

I’m Not Withholding on You: Employment Tax Enforcement Remains a Priority

By Michelle F. Schwerin / June 26, 2018 / Comments Off on I’m Not Withholding on You: Employment Tax Enforcement Remains a Priority

Last week, I had the pleasure of attending the New York University 10th Annual Tax Controversy Forum and hearing Paul Mamo, Director of Collection in the Internal Revenue Service, speak on developments in employment tax enforcement. Over the past few years, the IRS initiated an “Early Interaction Initiative” with respect to employment tax obligations.  In…

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South Dakota v. Wayfair: The End of the “Physical Presence” Test and the Future Reach of Sales Tax

By Michelle F. Schwerin / June 21, 2018 / Comments Off on South Dakota v. Wayfair: The End of the “Physical Presence” Test and the Future Reach of Sales Tax

In a 5-4 decision this morning, the Supreme Court upheld the South Dakota law requiring certain retailers to collect and remit sales tax regardless of whether the retailer had a physical presence.  The Supreme Court characterized the “physical presence” test as “unsound and incorrect”. History on the Matter In 1967, the Supreme Court first determined…

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Take Two: AICPA Tries Again for IRS Guidance on Virtual Currency Taxation

By Sanford J. Boxerman / June 14, 2018 / Comments Off on Take Two: AICPA Tries Again for IRS Guidance on Virtual Currency Taxation

About two weeks ago, the American Institute of Certified Public Accountants – “the world’s largest member association representing the accounting profession,” – sent a letter to the Internal Revenue Service, along with a document entitled “Request for Guidance Regarding Virtual Currency”. As discussed below, in its recent letter the AICPA adopted an approach which I…

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