Search Results for: 3520 penalties
John Doe Summons: A potent investigative tool used by the IRS
…severe civil penalties under IRC § 6662, and willful noncompliance may trigger a criminal investigation under IRC § 7201, potentially resulting in fines and imprisonment. This development serves as a…
Improving Voluntary Compliance: Reform the IRS Criminal Voluntary Disclosure Practice
…hurdles have made the program less appealing, particularly to taxpayers who are hesitant to expose themselves to potential penalties without clear guidance on outcomes. The changes to the VDP have…
Live Webinar on U.S.-India Tax Planning: Key Issues, Tax Treaties: Limited Free Registrations Available
…misapplication of domicile rules can be costly. Tax advisers serving clients in the U.S. and India will need to understand the domicile rules to avoid costly taxes and penalties. Other…
Taxpayer Wins Form 5471 Penalty Case
…the taxpayer, Mr. Mukhi, submitted delinquent Forms 5471 under protest for foreign corporations he had established. Despite this, the IRS assessed $120,000 in penalties under the aforementioned Code section. Upon…
Analysis of the Revised Form 14457: Key Changes to the IRS Voluntary Disclosure Practice
…aligns with the IRS’s enforcement priorities under IRC § 6663 (civil fraud penalties) and/or IRC § 7201 (criminal tax evasion). Civil Standard of Willfulness: Willfulness under IRC § 6663 encompasses…
IRS Changes Rules (Again) for Forms 1099-K Issuance from Venmo, Paypal, etc.
…from online platforms and peer-to-peer apps. Seek Professional Advice: If you receive multiple Forms 1099-K or have complex transactions, consult a tax professional to ensure accurate reporting and avoid penalties….
Middlesex County Man Admits Structuring over $250,000 in Deposits to Evade Reporting Requirements
…like this emphasize the importance of compliance with federal reporting laws and serve as a reminder that even seemingly minor attempts to bypass legal requirements can carry substantial penalties. Mitigating…
IRS Form 3520: How to sign and file the form
…IRS. Beware 3520 penalties. The penalties for failing to file Form 3520 (Annual Return to Report Transactions with Foreign Trusts and Receipt of Certain Foreign Gifts) can be quite severe,…
New IRS Website for New Immigrants to the United States: Key Tax Responsibilities
…appropriate tax withholding. If you are self-employed or earn significant income not subject to withholding, you may need to make estimated tax payments throughout the year to avoid penalties. The…
IRS Quietly Changes its Voluntary Disclosure Practice For the Worse
…benefit of reduced penalties compared to those imposed through audits or criminal investigations, helping taxpayers resolve liabilities more predictably and possibly with lower penalties. The VDP assesses a single one-year…
New IRS Voluntary disclosure program for employee retention credit
…the ERC amount. The IRS will waive penalties. Companies that participate in this program and amend their federal income tax returns for the applicable year to reinstate the deduction for…
US Supreme Court Will Favor Taxpayer Challenges to the IRS
…more detailed explanations and justifications for their interpretations to withstand judicial scrutiny. Accuracy-Related Penalties: Taxpayers could challenge the imposition of accuracy-related penalties, arguing that the IRS’s interpretation of the reasonable…