Search Results for: streamlined filing compliance procedures
Traveling? Resolve Tax Debt Before Getting Your Passport
…implementing new procedures affecting individuals with “seriously delinquent tax debts.” These new procedures implement provisions of the Fixing America’s Surface Transportation (FAST) Act. The law requires the IRS to notify…
Parag Patel Esq. Speaks to New Jersey Society of Certified Public Accountants (NJCPA) Nonprofit Interest Group
…tax and compliance requirements that apply to tax-exempt, not-for-profit entities. The program covered new tax court decisions, recent IRS publications, the latest tax legislation that will impact tax-exempt entities, IRS…
Opt Out of OVDI Program Penalties to Get a Lower Penalty
…will evaluate the file for a potential audit and imposition of appropriate penalties. The 2012 OVDP program continues the procedures announced in 2011 regarding decisions to “opt out” of the…
Tax Court Rules IRS Cannot Assess or Collect Form 5471 Penalties
…Form 5471, the taxpayer has 90 days after the notice is mailed to comply with the filing requirement. Failure to comply within the 90-day period subjects the taxpayer to an…
The Dreaded IRS Letter 6185: “We received information that you have a foreign account”
…in possession of records that identify taxpayers with transactions or accounts at offshore private banks. Soft letters are IRS correspondence to targeted taxpayers identifying tax noncompliance and passively seeking compliance….
IRS International Fines Not Excessive: Form 3520 Penalties Upheld, Form 5471 Penalties Again Unassessable
International tax reporting requirements are complex, and the penalties for non-compliance can be severe. In Mukhi v. Commissioner of Internal Revenue, the U.S. Tax Court considered a case involving a…
Beware IRS Letter 6291
…targeted taxpayers identifying tax noncompliance and passively seeking compliance. Failure to respond to such letters may result in audit or penalties and possible criminal prosecution. However, prior to audit, taxpayers…
Trinidad and Tobago and the United States sign new agreement to exchange of information under FATCA
Last week Trinidad and Tobago and the United States signed an agreement to facilitate automatic exchange of information under the US Foreign Account Tax Compliance Act (FATCA). FATCA, enacted by…
Secret Swiss Bank Accounts are No Longer Secret
…taxpayers to transfer funds abroad. In 2008, the Tax Division, in cooperation with the United States Attorneys’ offices, began the Offshore Compliance Initiative. The goal of the program was to…
No More Delays for FATCA: Get Ready for Disclosure
The US Foreign Account Tax Compliance Act (FATCA) will definitely come into effect on 1 July this year with no possibility of further delay, according to officials of the US…
New IRS Subpoenae and IRS Data Mining Expected
…disclosure of offshore assets. The OVDP, SDOP and SFOP compliance programs should be considered with experienced legal counsel. Patel Law Offices has consulted with hundreds of clients regarding their offshore…
Fantastic Recommendations for Form 3520
…the application of first-time abatement, the rules for managerial approval under section 6751(b), and compliance with Internal Revenue Manual provisions, and after the Office of Servicewide Penalties took action, Appeals…
Beware: India to sign FATCA agreement with US for sharing of information
…Account Tax Compliance Act (FATCA). Indian Finance Minister Arun Jaitley this week said India was not a tax haven and that taxes that were payable by foreign investors should be…
US Entities with foreign assets have more information reporting
…effective immediately, are linked to the Foreign Account Tax Compliance Act (FATCA). When FATCA was enacted in 2010, the new Section 6083D was added to the Internal Revenue Code requiring…
What FATCA Means to You and Your Investments
…the Foreign Account Tax Compliance Act (FATCA), which will allow automatic exchange of tax information between the two countries this year. FATCA is an important part of the US government’s…
Bank Leumi: Another Foreign Bank Recommends the IRS Voluntary Disclosure Program
…media, U.S. authorities are conducting investigations of foreign banks in connection with compliance with U.S. tax laws,” the bank said in the letter. The Leumi letter to clients said: “The…
Parag Patel Esq. speaks at NJCPA Tax Seminar: “Under the IRS Microscope: International Tax Reporting Update” and “What Tax Professionals Should Know About Trusts and Estates”
…property focusing on what you should know about trusts and estates. DESIGNED FOR All CPAs and tax professionals BENEFITS Learn best practices for international tax compliance of foreign income and…
India and US signed FATCA Agreement Today
India and the US today signed an agreement to implement the Foreign Account Tax Compliance Act (FATCA) that will facilitate exchange of information between the two countries starting on October…
New Court Ruling: FBAR penalties applied per form and not per account
The FBAR rules require the filing of a FinCEN Report 114, Report of Foreign Bank and Financial Accounts (FBAR) to report for accounts of U.S. persons aggregating $10,000 or more….
The IRS is Assessing Form 3520 Foreign Information Reporting Penalties
The IRS is aggressively sending out IRS Notice CP15 “Notice of Penalty Charge” for the late filing of Form 3520 to report the receipt of a foreign gift or foreign…
New Unreported Offshore Assets case: Bad facts leads to bad results
…than $10,000, by filing a FBAR, or Foreign Bank Account Report. Enforcement of this law increased after the signing into law of the Foreign Account Tax Compliance Act, or FATCA,…
New Jersey Tax Amnesty program
…taxes or file past returns with no penalties and reduced interest. “We are pleased to offer taxpayers a chance at compliance and a fresh start through the New Jersey Tax…
HSBC customer Josephine Bhasin Criminal Sentencing Very Light
HSBC customer Josephine Bhasin was sentenced last month. Josephine Bhasin of New York earlier pleaded guilty before U.S. Magistrate Judge E. Thomas Boyle in Central Islip, N.Y., to filing a…
US DOJ Tax Asst Attorney General Keneally Reports that One third of Swiss Banks Joining US DOJ Swiss Bank Program
…Swiss bank account should strongly consider disclosing that account now through the IRS Offshore Voluntary Disclosure Program (OVDP). The OVDP is a voluntary compliance initiative whereby individuals can receive amnesty…
How to Avoid Jail and Clean Up Tax Problems
…14457 is a Noncompliance Narrative Statement (Question 7 on Part II of the Form). The Narrative Statement must give (a) the taxpayer’s personal and professional background, (b) professional advisors, and…
The Misunderstood Extension of time to file FinCEN Form 114, Report of Foreign Bank and Financial Accounts (FBAR)
…“persons” for most tax purposes. Automatic Extension of Filing Deadline to October 15. Until last year, FBARs were generally due on June 30, with no automatic extensions available. In 2015,…
New US-Malta Agreement Targets Pension Planning by US Taxpayers
…in these arrangements. These taxpayers should consult an independent tax advisor prior to filing their 2021 tax returns and take appropriate corrective actions on prior filings. The IRS also cautions…
The Tax Issues of Expatriation
…your lawful permanent resident status by filing Department of Homeland Security Form I-407 with a U.S. consular or immigration officer, and the Department of Homeland Security determined that you have,…
Checklist of tax forms for taxpayers with foreign assets
…various types of investment accounts, and potentially other assets such as rental properties and foreign insurance policies. Form 8938 also differs in that it’s included along with your 1040 filing…
Should I close my foreign account?
…voluntary disclosure program and paying a 27.5 percent penalty on your highest account balance? At tax return filing time, should you check the box on Schedule B noting that you…