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International Tax Blog

Andrew Mitchel LLC is a law firm of international tax attorneys with extensive experience in international tax planning.

Failures To Adjust For Inflation

If Congress pursues tax reform this year, it should consider allowing inflation adjustments for the items discussed below. 

Each year, the IRS publishes inflation adjustments that modify the tax law as originally enacted.  We regularly post about the inflation adjustments in the international tax arena.  However, there are some significant values in the international tax area that are not adjusted for inflation.  In one case, the value has remained unchanged for over eighty years.Read more

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U.S. Government Continues To Pursue Taxpayers Committing Tax Fraud

As we have reported in past years the U.S. government actively pursues taxpayers that are committing tax fraud.  The Justice Department publicizes its successes in its press releases.  The press releases continue to demonstrate an impressive list of tax-related convictions, guilty pleas, injunctions, summonses, and other actions against taxpayers (and tax preparers).  Many of the tax fraud schemes include offshore activities.

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5 New Tax Charts

Today we added 5 new situational charts to andrewmitchel.com dealing with Section 987 Branch Transactions.

  • Reg. 1.987-1(b)(7), Example 1 (Not a Section 987 QBU: Disregarded Entity Holding Stock & Servicing a Debt)
  • Reg. 1.987-1(b)(7), Example 2 (Section 987 QBU: Disregarded Entities with Active Businesses)
  • Reg.
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Updated – IRS Practice Units By Topic

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Blind Guesses Are Not Good Faith Estimates

Continuing our series on Famous Tax Quotes (quotes from court opinions and rulings with language that is colorful or that concisely states an important tax principle) today’s tax quote is:

Although the nature of an estimate is such that the estimate does not guarantee that the true value of the thing being estimated will equal that predicted in the estimate, the estimate does carry an implied assertion that its author knows facts that justify the selection of the particular value chosen as the estimate.

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