Showing 4 posts in Tax Controversy & Litigation.
IRS Opens Determination Letter Program for Cash Balance Plans, Pension Equity Plans, and Certain Merged Plans
In 2017, the IRS eliminated the ability of sponsors of individually-designed qualified retirement plans to apply for favorable determination letters other than when a plan is first adopted or is terminated. Read More ›
The Kentucky Supreme Court, in Department of Revenue v. Mark F. Sommer, upheld all lower court decisions requiring the Department of Revenue (DOR) to make its redacted final rulings publicly available. The Court ruled that the state DOR took an “unreasonable and overly broad view” of public records statutes and later denied the department’s request for appeal. Read More ›
Are You Withholding Too Much on Nonqualified Deferred Compensation?
If you have a nonqualified deferred compensation plan for select employees, you are probably aware that benefit payments under a properly structured plan are generally not taxable for income tax purposes until the payments are received by the employee. Read More ›
On March 26, 2009, the IRS announced an Offshore Income Reporting Initiative to encourage taxpayers with undeclared offshore accounts and assets to come forward and participate in the IRS voluntary disclosure program. Read More ›
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Mark F. Sommer is FBT’s Tax, Benefits and Estates Practice Group leader, focusing on state, local and federal tax, incentives, tax controversy and litigation. He has successfully handled thousands of audits, protests, appeals, and transactional matters.