In recent court filings made in various federal district courts in Washington and California, the Internal Revenue Service is seeking to enforce testimonial summonses issued to current or former Microsoft employees, including former CEO Steven A. Ballmer. The summons had been issued earlier this fall. Microsoft’s outside tax counsel responded to the summonses by stating that the various witnesses would not be made available to the Service. The summonses were issued to obtain information […]

Recently the Canada Revenue Agency (CRA) provided some written guidance on the income tax treatment for taxpayers that unknowingly make an investment in a fraudulent investment scheme, including Ponzi or Ponzi-like schemes (See CRA Technical Interpretation Document No. 2014-0531171M6 dated July 3, 2014).The rules will apply to taxpayers who had what reasonably appeared to be legitimate investments for income tax purposes. These guidelines will not apply to taxpayers who knowingly participated in a scheme […]