Posts Tagged Penalties

Court Denies Basis To Partners For Contributions of Notes, But Waives Penalties

The Tax Court has denied basis to individuals who contributed unfunded, unsecured notes to a partnership and claimed basis for the amounts on the notes. As a result, the partners’ bases in their partnership interests were too low for them to claim greater pass-through losses on their…

Read more

IRS’ Overhaul of Streamline & Offshore Voluntary Disclosure Program “OVDP”

On June 18, 2014, the IRS announced comprehensive changes to both the Streamlined and the Offshore Voluntary Disclosure Program (“OVDP”) programs. Such changes to the Streamline Program include: Streamlined Program 1. Expanded to include both U.S. citizens living abroad and U.S. citizens living in the United States…

Read more