30-DAY LETTERS VS. 90-DAY LETTERS IN TAX AUDITS
In a tax audit situations, the IRS only has a 3 year statute of limitations to assess additional taxes. If the IRS takes too long to initiate an audit, or the audit drags on too long, the taxpayer may lose
Reasons to Opt Out of the 2011 OVDI Program
Top 4 Reasons to Opt Out of the 2011 OVDI Program 1. The IRS Taxpayer Advocate’s Report: Although the IRS has not closed very many opt-out cases, the average civil FBAR penalty assessed against those opting out of the 2009 OVDP
Opt Out of OVDI Program Penalties to Get a Lower Penalty
Under the 2011 Offshore Voluntary Disclosure Initiative (OVDI) or 2012 Offshore Voluntary Disclosure Program (OVDP), the 2012 program gives no discretion to the IRS agents to reduce penalties. If a participant does not believe that he or she should have
FBAR Deadline is June 28, 2013
This month we remind taxpayers of the upcoming June 30, 2013 deadline for filing Form TD F 90-22.1, Report of Foreign Bank and Financial Accounts (FBAR), to report financial interests in, or signature authority over, foreign financial accounts. There is
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Recent Posts
- Changes to Legal Documents in light of the Coronavirus pandemic March 29, 2020
- US FATCA Enforcement Softens due to Coronavirus March 25, 2020
- Planning in the Time of Coronavirus March 17, 2020
- IRS Reduces Administrative Burden (for the first time) of Filing Some Forms 3520 and/or Forms 3520-A March 4, 2020
- Planning for Dependent (or not Independent) Family Members March 2, 2020
- The IRS is Assessing Form 3520 Foreign Information Reporting Penalties February 21, 2020
- 2020 New Year’s Tax Planning Resolutions: Resolve To Plan Better January 27, 2020
- The InSECURITY of the SECURE Act January 24, 2020
- Are You Ready For New FATCA Enforcement in 2020? January 2, 2020
- No Clawbacks for Gifts if Estate Tax Exemption Changes December 27, 2019
- Reasonable Cause Defense Denied: FBAR Penalties Assessed by Court December 19, 2019
- IRS announces two new intriguing targeted enforcement campaigns September 12, 2019