This week, the scientific community announced two projects that may have important implications on the future of stem cell research and the development of effective treatments for orthopedic trauma and blood-related disorders. These projects signal a continued effort by researchers to improve our understanding of the body’s basic mechanisms for producing hematopoietic stem cells (HSCs), which are multipotent cells that have the ability to replenish all blood cell types.
https://fidjlaw.com/wp-content/uploads/2007/02/FIDJ-Logo-Hero.svg00admin_fidjhttps://fidjlaw.com/wp-content/uploads/2007/02/FIDJ-Logo-Hero.svgadmin_fidj2011-06-20 12:25:382025-12-09 14:29:34Researchers Continue to Look to Stem Cells for Clues for Effective Treatments of Orthopedic Trauma and Blood-Related Disorders
In its crusade to rein in foreign asset reporting, the IRS moved closer to implementing a new reporting measure called for by the Foreign Account Tax Compliance Act of 2010. Meanwhile, FinCEN granted an FBAR reporting extension to certain employees of investment advisors.
After considering more than 50 written comments on the proposed Circular 230 revisions, the Treasury and the IRS released final regulations on May 31, 2011. Notably, the regulations establish a new “registered tax return preparer” designation. Sections 10.3-10.6 of Circular 230 describe the process for becoming a registered tax return preparer (“Registered Preparer”) and the limited practice rights associated with the designation.
At the first annual Transfer Pricing Conference in Washington on June 8, current and former IRS officials explained recent initiatives in the Advance Pricing Agreement Program (APA).
https://fidjlaw.com/wp-content/uploads/2007/02/FIDJ-Logo-Hero.svg00admin_fidjhttps://fidjlaw.com/wp-content/uploads/2007/02/FIDJ-Logo-Hero.svgadmin_fidj2011-06-17 07:13:382025-12-09 14:26:53Panelists Address New Approaches to Increasing Efficiency of U.S. APAs
On June 13, 2011, Joseph A. DiRuzzo, III, a Senior Tax Associate at Fuerst Ittleman, PL filed his Initial Brief in the Third Circuit Court of Appeals in Gangi v. United States of America, 3d. Cir. case # 11-1612.
https://fidjlaw.com/wp-content/uploads/2007/02/FIDJ-Logo-Hero.svg00admin_fidjhttps://fidjlaw.com/wp-content/uploads/2007/02/FIDJ-Logo-Hero.svgadmin_fidj2011-06-17 07:10:162016-06-03 14:59:29Third Circuit to consider Constitutionality of IRS Summons Issued in U.S. Virgin Islands Economic Development Credit Case
On June 10, 2011, the Third Circuit Court of Appeals in Appleton v. Commissioner, overturned the U.S. Tax Court which had denied the Government of the U.S. Virgin Islands motion […]
https://fidjlaw.com/wp-content/uploads/2007/02/FIDJ-Logo-Hero.svg00admin_fidjhttps://fidjlaw.com/wp-content/uploads/2007/02/FIDJ-Logo-Hero.svgadmin_fidj2011-06-14 16:34:392025-12-09 14:24:07Third Circuit Court of Appeals overturns U.S. Tax Court regarding Virgin Islands Economic Development Program case
A New Jersey jury found two dietary supplement companies guilty of several counts of criminal contempt for violating a consent decree, see Department of Justice announcement. A consent decree is an agreement wherein the defendant agrees to take voluntary action to remedy nonconformance and, in turn, settles a pending civil suit with the government. Criminal contempt generally refers to conduct that defies or disrespects the court and impedes the administration of justice.
https://fidjlaw.com/wp-content/uploads/2007/02/FIDJ-Logo-Hero.svg00admin_fidjhttps://fidjlaw.com/wp-content/uploads/2007/02/FIDJ-Logo-Hero.svgadmin_fidj2011-06-14 14:00:042025-12-09 14:26:45Two Dietary Supplement Companies Found Guilty of Criminal Contempt for Violating Consent Decree
On June 7, 2011, Steven Miller, deputy commissioner for services and enforcement, announced the next IRS strike in its battle against offshore tax evasion. Miller stated that the agency is planning an enforcement action against one or more non-U.S. banks in the next month.
https://fidjlaw.com/wp-content/uploads/2007/02/FIDJ-Logo-Hero.svg00admin_fidjhttps://fidjlaw.com/wp-content/uploads/2007/02/FIDJ-Logo-Hero.svgadmin_fidj2011-06-14 13:32:512025-12-09 14:24:07IRS Prepares Enforcement Against at Least One Foreign Bank
The AICPA submitted a comment letter last week calling for the Financial Crimes Enforcement Network (“FinCEN”) to reduce or eliminate select filings of Report of Foreign Bank and Financial Account (“FBAR”) for 2009 and prior years. The AICPA’s comments come as the deadline approaches for filers who previously deferred from the June 30, 2010 and June 30, 2009 deadlines under Notices 2010-23 and 2009-62. Now, those filers are under the gun to analyze their data and determine appropriate filing or non-filing positions before June 30, 2011. The AICPA proposes waiving the filing requirement for those with signatory authority over, but no financial interest in, a foreign bank or financial account.
As the August 31, 2011 deadline nears, the IRS has announced that taxpayers may request a 90-day extension to participate in the 2011 Offshore Voluntary Compliance Initiative (“OVDI”). The IRS also laid out guidance for taxpayers to opt out of the disclosure program as well as circumstances when the Service will remove taxpayers from the program.
Researchers Continue to Look to Stem Cells for Clues for Effective Treatments of Orthopedic Trauma and Blood-Related Disorders
This week, the scientific community announced two projects that may have important implications on the future of stem cell research and the development of effective treatments for orthopedic trauma and blood-related disorders. These projects signal a continued effort by researchers to improve our understanding of the body’s basic mechanisms for producing hematopoietic stem cells (HSCs), which are multipotent cells that have the ability to replenish all blood cell types.
Foreign Asset Reporting Update: IRS Releases Form 8938, FinCEN Grants FBAR Extension for Some Investment Advisors
In its crusade to rein in foreign asset reporting, the IRS moved closer to implementing a new reporting measure called for by the Foreign Account Tax Compliance Act of 2010. Meanwhile, FinCEN granted an FBAR reporting extension to certain employees of investment advisors.
IRS Releases Final Circular 230 Revisions Regulating Registered Tax Return Preparers
After considering more than 50 written comments on the proposed Circular 230 revisions, the Treasury and the IRS released final regulations on May 31, 2011. Notably, the regulations establish a new “registered tax return preparer” designation. Sections 10.3-10.6 of Circular 230 describe the process for becoming a registered tax return preparer (“Registered Preparer”) and the limited practice rights associated with the designation.
Panelists Address New Approaches to Increasing Efficiency of U.S. APAs
At the first annual Transfer Pricing Conference in Washington on June 8, current and former IRS officials explained recent initiatives in the Advance Pricing Agreement Program (APA).
Third Circuit to consider Constitutionality of IRS Summons Issued in U.S. Virgin Islands Economic Development Credit Case
On June 13, 2011, Joseph A. DiRuzzo, III, a Senior Tax Associate at Fuerst Ittleman, PL filed his Initial Brief in the Third Circuit Court of Appeals in Gangi v. United States of America, 3d. Cir. case # 11-1612.
Third Circuit Court of Appeals overturns U.S. Tax Court regarding Virgin Islands Economic Development Program case
On June 10, 2011, the Third Circuit Court of Appeals in Appleton v. Commissioner, overturned the U.S. Tax Court which had denied the Government of the U.S. Virgin Islands motion […]
Two Dietary Supplement Companies Found Guilty of Criminal Contempt for Violating Consent Decree
A New Jersey jury found two dietary supplement companies guilty of several counts of criminal contempt for violating a consent decree, see Department of Justice announcement. A consent decree is an agreement wherein the defendant agrees to take voluntary action to remedy nonconformance and, in turn, settles a pending civil suit with the government. Criminal contempt generally refers to conduct that defies or disrespects the court and impedes the administration of justice.
IRS Prepares Enforcement Against at Least One Foreign Bank
On June 7, 2011, Steven Miller, deputy commissioner for services and enforcement, announced the next IRS strike in its battle against offshore tax evasion. Miller stated that the agency is planning an enforcement action against one or more non-U.S. banks in the next month.
AICPA Submits FBAR Comment Letter
The AICPA submitted a comment letter last week calling for the Financial Crimes Enforcement Network (“FinCEN”) to reduce or eliminate select filings of Report of Foreign Bank and Financial Account (“FBAR”) for 2009 and prior years. The AICPA’s comments come as the deadline approaches for filers who previously deferred from the June 30, 2010 and June 30, 2009 deadlines under Notices 2010-23 and 2009-62. Now, those filers are under the gun to analyze their data and determine appropriate filing or non-filing positions before June 30, 2011. The AICPA proposes waiving the filing requirement for those with signatory authority over, but no financial interest in, a foreign bank or financial account.
IRS Relaxes Deadline for 2011 Offshore Voluntary Disclosure Initiative, Provides Opt Out and Removal Procedures
As the August 31, 2011 deadline nears, the IRS has announced that taxpayers may request a 90-day extension to participate in the 2011 Offshore Voluntary Compliance Initiative (“OVDI”). The IRS also laid out guidance for taxpayers to opt out of the disclosure program as well as circumstances when the Service will remove taxpayers from the program.