Tax

The Franchise Tax Board of California has announced the Voluntary Compliance Initiative 2 (VCI 2) as an opportunity for taxpayers with underreported California tax liabilities relating to either (i) abusive tax avoidance transactions (ATATs) or (ii) offshore financial arrangements (OFAs), to amend their tax returns...

On August 31, the IRS Offshore Voluntary Disclosure Initiative is closing. The Initiative allows U.S. taxpayers with unreported income relating to undisclosed foreign bank or financial accounts to make a voluntary disclosure to get current with their taxes and information filing obligations for the past...

Overview of Offshore Voluntary Disclosure Initiative On June 2, the IRS updated the Q&A’s describing the 2011 Offshore Voluntary Disclosure Initiative.  The initiative is discussed in more detail in our March 3rd blog post, but generally, it is a program that allows taxpayers with undisclosed foreign...

Versata v. Selectica Court Case In a recent Delaware Supreme Court case, Versata v. Selectica, (10/4/2010 Del. Sup. Ct.) 5 A.3d 586, the court approved Selectica’s use of a net operating loss (NOL) preservation plan. The plan essentially allowed Selectica to issue diluting shares to existing...

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