Search Results for: irs appeal
Another HSBC Customer Likely Going to Jail
…2011 to conspiring with five HSBC bankers to hide his Indian accounts from the IRS. His plea came four days after a U.S. judge in California allowed the IRS to…
Protective Filing of Information Returns
There is an increased focus by the Internal Revenue Service (IRS) on offshore activities. There are tax return and information return filing obligations that may be associated with foreign income,…
IRS Clarifies Requirements for Streamlined Filing Procedures
Our office has received many inquiries from taxpayers interested in the Streamlined Filing Compliance Procedures with the new lower penalty. However IRS guidance and instructions was unclear and ambiguous in…
IRS Advisory: Prepaid Real Property Taxes May Be Deductible in 2017 if Assessed and Paid in 2017
…signed last week in Washington prohibited the deduction of prepaid state and local income taxes. However the new law was silent on the prepayment of property taxes. The IRS has…
“Willfulness” When Deciding Whether to Opt Out of 2011 OVDI
…The appeals officer will give the taxpayer an opportunity to present his case, conduct an appeals conference, and issue a decision. As far at the IRS is concerned, the appeals…
National Taxpayer Advocate Identifies OVDP Program as a Serious Problem
…the “one-size-fits-all” approach of the IRS Offshore Voluntary Disclosure Program (OVDP), and identified the OVDP program as a most serious problem requiring resolution. The Report states that the IRS discouraged…
National Taxpayer Advocate Criticizes IRS over handling of offshore voluntary disclosures
The 2012 National Taxpayer Advocate (NTA) Annual Report to Congress criticized current IRS practices in the Offshore Voluntary Disclosure Program (OVDP) that hinder voluntary compliance by penalizing taxpayers who are…
Opting Out of the Offshore Voluntary Compliance Initiative Programs
As with other IRS’ 2009 and 2011 offshore voluntary compliance initiatives, the 2012 program gives no discretion to the IRS agents to reduce penalties. If a participant does not believe…
Are You Ready For New FATCA Enforcement in 2020?
Banks and certain other financial institutions located outside the United States that have U.S. account holders are scrambling to meet a looming IRS deadline. These institutions, known as foreign financial…
Silent Disclosure: The Qualified Amended Return (QAR)
Can I Disclose Issues to the IRS After the Tax Return Is Filed? This question is very important for our clients exploring silently disclosing previously unreported income on an amended…
New Form 3520 Penalties
In November 2020, the IRS changed the rules for assessing penalties for Form 3520, the Annual Return to Report Receipt of Foreign Gifts. Form 3520 is filed for any U.S….
Another Swiss Bank Discloses Customer Names to the US
…its noncompliant U.S. account holders must now pay that 50 percent penalty to the IRS if they wish to enter the IRS’ program. Once a bank becomes the publicly announced…
Numerous Criminal Prosecutions of Taxpayers with Unreported Offshore Accounts
…and Cohen-Levy was ordered to pay restitution of $7.8 million. Both father and son have filed appeals (Cohen Assor 11-10729-F, Cohen-Levy 11-10731-F) to the 11th Circuit. The two appeals have…
New Mandatory E-filing Form 8300 for Reporting of Large Cash Currency Transactions
The IRS announced yesterday that certain businesses that receive payments of over $10,000 in cash must file Form 8300, Report of Cash Payments Over $10,000 Received in a Trade or…
Fifth HSBC India Customer indicted for tax evasion this year
…for U.S. taxpayers with undisclosed HSBC accounts to take advantage of the IRS Voluntary Disclosure Program for offshore accounts. The IRS says there are 9,000 high net worth Indian US…
Canada and US sign FATCA tax deal where banks to share information with IRS
…July and the Canada Revenue Service will begin reporting to the IRS in 2015. The agreement will not require changes to Canadian laws, but will need Parliament’s approval. Our firm…
Taxpayers Advised to Use Caution: Confirmed FBAR Information Request Scam
…should not reply. The IRS has asked that all unsolicited email claiming to be from the IRS be reported to phishing@irs.gov. Additional information can be located at the IRS website….
The Risks of “Opting Out” of OVDI
…FBAR be brought as a civil case in the United States District Court, rather than under the assessment provision of the Code. The IRS in its FBAR Frequently Ask Questions…
All the Many FBAR Late Filing Procedures
…person’s immigration status, however this is extremely rare. To learn more about the VDP go to: https://patellawoffices.com/blog/planning-for-tax-minimization/irs-updated-voluntary-disclosure-practice-is-a-game-changer/ Reasonable Cause Submission This is not an actual IRS voluntary disclosure program but…
Method to Cure Delinquent or Incomplete Foreign Information Returns Without Penalties
Last year, the IRS announced its third offshore voluntary disclosure initiative. Like the earlier initiatives, the 2012 OVDP is designed to encourage taxpayers with unreported offshore accounts and assets to…
New FinCEN Form 114 (FBAR) Filing Rules Announced
…procedures Delinquent FBARs The IRS on July 24, 2013 updated its Frequently Asked Questions (FAQs) for its Offshore Voluntary Disclosure Program (OVDP). Under the OVDP’s 2012 announcement, the IRS provided…
Top myths of US tax compliance for Foreign Accountholders
…your lack of filing was non-willful (which can be sometimes tricky). Myth #4: The IRS can’t find me because I live abroad. The IRS has a new way to pursue…
IRS Announces Increased Enforcement on Form 5471
On April 16, 2019, the Large Business and International (LB&I) Division of the Internal Revenue Service (IRS) announced a new compliance campaign to focus on the separate detach filing of…
Top 10 factors to consider before deciding to opt out of OVDI or OVDP
…the IRS agent assigned to a submission made under OVDI or OVDP, the IRS will be in a position to gauge the strength of the taxpayer’s reasonable cause argument, which…
Most Swiss banks participating in the US Department of Justice (DOJ) amnesty program seek extension to disclose
…obtained from banks to identify, audit, and prosecute noncompliant individuals. If the IRS identifies you noncompliance through the amnesty program you face near certain IRS scrutiny, significant liabilities, severe and…
Swiss Banks’ Deadline to Disclose Information is Extended
…to participate in the OVDP. The IRS and DOJ will continue to gather and use the information obtained from banks to identify, audit, and prosecute noncompliant individuals. If the IRS…
Eleven foreign financial institutions to share their US customer account information
…Handing Over Client Data The IRS reported that eight Swiss banks, including Credit Suisse, Julius Baer, and Basler Kantonalbank turned over US client data on taxpayers suspected of tax evasion…
Cayman Islands Advisors Arrest Suggest U.S. Government Receiving More Information About Offshore Accounts
According to a DOJ Tax Press Release, here, the IRS has arrested a U.S. Citizen and two Canadian citizens who offered enabler services to U.S. taxpayers. They were caught in…
IRS attempts to demystify its new Form 8938
The IRS has finally attempted to demystify its new Form 8938. Below are some Form 8938 FAQs: Basic Questions and Answers on Form 8938 1. What are…
The “Quiet” or “Silent” Disclosure
…hopefully avoid further IRS scrutiny (i.e., an audit whereby the IRS decides whether to impose the statutory penalties). By making a “quiet” disclosure, a taxpayer runs the risk of being…