2018-05-29 SALT Battles Begin

This week we look at the following items:

• FBAR penalty limited to lower amount in old regulation
• Taxpayer had not started a business yet, so no current deduction allowed for expenses incurred
• IRS to issue regulations on SALT/charity workarounds, raises substance over form issue
• DC Circuit agrees with Ninth Circuit that partnerships with disregarded entity partners are subject to TEFRA (and presumably subject to CPAR) audits

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