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Is Bitcoin a Security? The SEC is a federal agency that regulates the securities markets within the United States. The SEC enforces certain disclosure requirements and financial filings in the name of protection against market manipulation. Issuers of securities need to be registered with the SEC, as well as financial service firms and the professionals … Continue reading Bitcoin: Efforts

The IRS announced its enforcement priorities include international reporting among the top two categories.  I have represented taxpayer’s in disputes with the IRS and state taxing agencies over international and domestic tax issues for decades.  What I have found is that there is a  group of taxpayer’s facing international penalties; immigrants (typically first generation U.S. … Continue reading International Enforcement

Don’t get me wrong, I am not suggesting that there is an equivalence in actions between Laurie Loughlin, whose underlying alleged[1] criminal activity involved bribery  in an effort to get her daughters into college and the conduct of an organized crime leader, but I am pointing out the common denominator, tax crimes.  The IRS-Criminal Investigation … Continue reading What do

Proposition XIII is under attack through a proposed amendment to the Constitution of the State of California. The proposed amendment is known as “The California Schools and Local Communities Funding Act of 2018” The proposed amendment would eliminate Prop 13 tax rate increases for “commercial and industrial properties” and would require reassessment to their full … Continue reading Proposition XIII

The Tax Cuts and Jobs Acts Eliminates the Tax Deduction for Spousal Support Beginning January 1, 2019, except for support Orders effective by December 31, 2018. For decades the Internal Revenue Code and the California Revenue and Taxation Code have allowed an income tax deduction to payors of “Spousal Support”. The recipient ex-spouse was required … Continue reading The Tax

The end of the Offshore Voluntary Disclosure Program (“OVDP”) may mean nothing at all to the hard core taxpayers who will never voluntarily come forward. For many of those individuals. who chose the “wrong” foreign financial institution or financial advisor the prospect of paying fifty percent (50%) of the highest account balance in the preceding … Continue reading The Offshore