The Trusted Professional

The Trusted Professional serves as the official publication for the New York State Society of Certified Public Accountants. It provides readers with the latest information on legislative, regulatory, and administrative changes, especially those related to tax and audit policies, as well as accounting practices in New York state. For more details, visit: http://www.nysscpa.org/news/publications#sthash.t6EpPen5.dpuf

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Penalties in Modern Tax Practice

Jun 3, 2024 | nysscpa.org | Melissa Wiley

“In 1955, there were approximately 14 penalty provisions in the Internal Revenue Code. There are now [in 2011] more than ten times that number.” Internal Revenue Manual (“IRM”) part 20.1.1.1.1.Whenever I am asked why it is that I speak so often about penalties, I highlight the above quote from the IRS’s employee handbook. Whereas there were 14 penalty provisions in 1955, approximately 150 were listed by 2011; there are even more now, 13 years later.
The YA Global Tax Court Decision: Private Fund Activities Drag Non-U.S .Fund Investors Into the U.S. Tax Net

Jun 3, 2024 | nysscpa.org | Mark Leeds

For U.S. history aficionados, November 15 is an auspicious day: It was on this day in 1777 that the Continental Congress approved the Articles of Confederation. These articles framed the basic form of government for what was to become the United States. Well, tax folks working with private funds are likely to remember November 15 for another reason as well. On this day in 2023, the Tax Court released its long-awaited decision in YA Global Investments, LP v.