K. Christy Vouri-Misso
Subscribe to K. Christy Vouri-Misso's Posts
K. Christy Vouri-Misso focuses her practice on all stages of complex federal tax controversies including Internal Revenue Service (IRS) examinations, administrative appeals, voluntary disclosures, and litigation. She has settled multiple tax disputes with IRS legal counsel avoiding costly litigation in court. Read K. Christy Vouri-Misso's full bio.
IRS is Required to Search Tax Return Information Records to Help Determine Worker Classification
By K. Christy Vouri-Misso, Robin L. Greenhouse and Ruth Wimer on Apr 7, 2017
Posted In Court Procedure Matters, IRS Audits, IRS Guidance, Tax Refunds, Uncategorized
On April 5, 2017, in an unanimous court reviewed opinion, the United States Tax Court determined that disclosure of a worker’s tax return information to absolve the employer from liabilities arising out of the employer’s withholding requirement is not subject to the general prohibition against disclosing taxpayer return information pursuant to Internal Revenue Code (IRC)...
Continue Reading
Court Holds that Willful Failure to File FBAR Standard is the Lesser Standard of Recklessness
By K. Christy Vouri-Misso on Dec 19, 2016
Posted In Appellate Courts, Trial Courts, Uncategorized
On December 2, 2016, the US District Court for the Central District of California found that taxpayers who failed to file a Report of Foreign Bank and Financial Accounts (FBARs) for three foreign accounts, one of which, in the court’s view, was intentionally kept secret from all persons except their children, for over a decade...
Continue Reading
CDFI Fund Announces $7 Billion Allocation of New Markets Tax Credits
By K. Christy Vouri-Misso and McDermott Will & Emery on Dec 9, 2016
Posted In Uncategorized
On November 17, 2016, the US Department of the Treasury’s Community Development Financial Institutions Fund (CDFI Fund) announced the largest single round award of New Market Tax Credit (NMTC) allocations since the program’s creation in 2001. One hundred twenty organizations, headquartered in 36 states, the District of Columbia and Puerto Rico, were awarded a total...
Continue Reading
More than 100,000 Taxpayers Become Compliant with Reporting and Tax Requirements, Paying more than $10.3 billion in Taxes, Interest and Penalties
By K. Christy Vouri-Misso on Nov 16, 2016
Posted In IRS Guidance, Uncategorized
On October 21, 2016, the Internal Revenue Service announced the most current data on the success of its Offshore Voluntary Disclosure Program (OVDP) and Streamlined Filing Compliance Procedures (SFCP) programs. For our prior coverage on the OVDP and SFCP programs please see Offshore Voluntary Disclosure Update and Release of “Panama Papers” May Encourage New Wave of OVDP...
Continue Reading
IRS and Treasury Release Update to 2016-2017 Priority Guidance Plan
By K. Christy Vouri-Misso and McDermott Will & Emery on Nov 2, 2016
Posted In IRS Guidance, Settlements, Uncategorized
The US Department of the Treasury and Internal Revenue Service (IRS) issue Priority Guidance Plans each year to identify and prioritize the tax issues they believe should be addressed through regulations, revenue rulings, revenue procedures, notices and other published administrative guidance. On October 31, 2016, the IRS and Treasury released the first quarter update to...
Continue Reading
Timing of a US Federal Tax Controversy
By K. Christy Vouri-Misso on Oct 18, 2016
Posted In Court Procedure Matters, Trial Courts, Uncategorized
Understanding the timing of a US Federal tax controversy is helpful in creating a sound and efficient strategy. This timeline shows the typical timing of a US Federal tax controversy, from the IRS’s examination of the return, through administrative appeals, litigation in Tax Court, Circuit Court appeal, and to ultimate assessment of tax.
Continue Reading
Tax Bar Has Serious and Substantial Comments to the Proposed IRC Section 385 Regulations
By K. Christy Vouri-Misso and Timothy S. Shuman on Jul 1, 2016
Posted In IRS Guidance, Transfer Pricing Resource, Uncategorized
On April 4, 2016, the Internal Revenue Service and the US Department of the Treasury issued proposed regulations pursuant to Internal Revenue Code (IRC) section 385 addressing whether an interest in a related corporation is treated as stock or indebtedness for US federal income tax purposes (Proposed Regulations). On June 29, 2016, both the DC...
Continue Reading
Court Attack On FATCA Fails
By K. Christy Vouri-Misso and Kevin Spencer on Apr 28, 2016
Posted In Court Procedure Matters, Trial Courts, Uncategorized
Senator Rand Paul (R-KY) and six other plaintiffs’ efforts to challenge parts of the Foreign Account Tax Compliance Act (FATCA) were thwarted when the US District Court for the Southern District of Ohio dismissed their claims for lack of standing. Crawford v. Dep’t of Treasury, S.D. Ohio, US District Court for the Southern District of...
Continue Reading
