Search Results for: irs appeal
The Misunderstood Extension of time to file FinCEN Form 114, Report of Foreign Bank and Financial Accounts (FBAR)
…not be extended unless the taxpayer files an extension request with respect to the underlying tax return. This includes IRS Form 8938 (Statement of Specified Foreign Financial Assets), IRS Form…
FATCA-Compliant Institutions List Goes Online
…to report. The IRS has published a searchable list of financial institutions. The FFI List Search and Download Tool is located on the IRS’s FATCA Website. The tool can be…
Quiet or Silent Disclosure Commentary from the Government Accountability Office
…to the IRS, and the IRS pays attention. Those recommendations could put some taxpayers in trouble. Particularly concerning is the Quiet Disclosure commentary. Below is an excerpt from the report….
Consequences of Filing False Streamlined Filings
The IRS Streamlined Domestic Offshore Program (“SDOP”) allows eligible U.S. Taxpayers who failed to disclose foreign financial accounts to voluntarily disclose their conduct to the IRS and pay a reduced…
IRS Streamlined Filing Compliance Procedures Seminar
The Internal Revenue Service announced major changes in its offshore voluntary compliance programs, providing new streamlined filing compliance procedures to help both taxpayers residing overseas and those residing in the…
US FATCA Enforcement Softens due to Coronavirus
…the IRS. Foreign banks that don’t have agreements with the agency to satisfy the requirements are subject to 30% withholding on payments made to them, according to the IRS. Our…
HSBC Customer Avoids Jail in Tax Evasion Case
…HSBC India helped Americans hide money from the Internal Revenue Service. Publicity over Dahake’s case helped spur 33,000 Americans with accounts at various banks to avoid prosecution through an IRS…
The Teeth of the Foreign Account Tax Compliance Act (FATCA)
…on the holdings of U.S. taxpayers. The IRS was recently forced to offer some relief from the onerous requirements for expatriates and dual citizens. The IRS has issued new proposed…
Employers Must Re-examine Employee Retention Credit (ERC) Claims
…IRS Crackdown The IRS is now aggressively focusing on these dubious claims: Increased audits of ERC filings. New claim processing paused. Criminal investigations launched against promoters and businesses associated with…
Beware of U.S. tax consequences to a foreign trust with a U.S. beneficiary
…U.S. recipient of a distribution from such a trust, fails timely file a Form 3520 to report these transactions, the IRS may impose a penalty equal to 35% of the…
Cost of Compliance Rises under OVDP
…a list of banks and institutions that trigger the higher 50-percent penalty under the OVDP. As we have previously noted, the IRS has a series of voluntary disclosure programs and…
Penalties for Form 5472 Information Return of a 25% Foreign-Owned U.S. Corporation or a Foreign Corporation Engaged in a U.S. Trade or Business
We would like to highlight a recent change in the IRS’ policy with respect assessing statutory late filing penalties related to certain international information forms. Of particular concern to international…
Article Discusses Termination of Offshore Voluntary Disclosure Program (OVDP) and the Streamlined Filing Compliance Procedures (SFCP)
…Meanwhile, the IRS has not commented on terminating OVDP or SFCP. The IRS has publicly stated that it may terminate the disclosure programs at any time. However, the termination of…
New US-Malta Agreement Targets Pension Planning by US Taxpayers
…from these schemes are not pensions or other similar remuneration. The IRS put taxpayers on notice earlier this year that it was reviewing the use of Maltese personal retirement schemes. The…
News from the 2014 Criminal Fraud and Tax Controversy Conference
…were in attendance. Below are some interesting observations: On the new IRS Streamlined program (including the SDOP and SFOP programs), David Horton LB&I director for international compliance (who is in…
Foreign Account Penalties Are Unfair
…government is realizing the unfairness of the offshore penalties. In her June 30, 2011 Report to Congress, U.S. Taxpayer Advocate Nina Olson criticizes the IRS over its Offshore Voluntary Disclosure…
Make Sure You have Filed FATCA Compliance Certifications
…foreign account and income data to the US IRS. As a result, foreign banking secrecy no longer exists: virtually all foreign banks report bank data to the IRS. Indian investors…
More Swiss Banks Agree to Cooperate with the IRS
Lombard Odier & Cie and VP Bank (Switzerland) last week became the latest Swiss banks to say they would work with U.S. officials in a crackdown on lenders suspected of…
HSBC India Customer New Indictment Uncovers More HSBC Details
…Federal prosecutors in Milwaukee filed a superseding nine-count indictment to defraud the IRS from 2006 to 2009 against Dr. Ahuja, a neurosurgeon in Greendale, Wisconsin, that fleshed out details of…
Beware the New 2023 Form 1099-K
Beginning in 2023, third-party payment networks must file Form 1099-K with the IRS and provide a copy to the taxpayer when the gross payment amount exceeds $600. However, not all…
Another Customer with Unreported Offshore Bank Accounts Pleads Guilty
George Landegger, CEO of pulp and paper company, pleaded guilty last week in New York to a federal charge of failing to file a required report to the IRS about…
Estate Tax Revisit
…percent to 45 percent. Almost half of their estate will fall into the hands of the IRS. But there is hope for them. First of all, among the estates that…
Corporate Transparency Act (CTA) Reporting Company Analysis and FAQs
…and allowances) on the entity’s IRS Form 1120, consolidated IRS Form 1120, IRS Form 1120-S, IRS Form 1065, or other applicable IRS form, excluding gross receipts or sales from sources…
IRS Announces Increased 2023 Gift Tax Annual Exclusion, Gift, and Estate Tax Exemptions
The Internal Revenue Service recently released the annual inflation adjustments for tax year 2023, which include welcome increases for wealth transfer tax planning. The gift tax annual exclusion will increase…
Answers to Common Questions for IRS CP3219N Notice of Deficiency (90-day letter)
What you need to do If you want to challenge the deficiency determination, file a petition with the Tax Court. File your tax return immediately (no later than 90 days…
No tax = No Passport?
…tax purposes. Most foreign banks will ultimately report U.S. depositor account information to IRS. The IRS will then be able to assess tax, interest and penalties on the unreported income…
IRS Reminds (again) Taxpayers to Report Foreign Income and Assets
Earlier this month on April 11, 2014, the Internal Revenue Service issued Notice IR-2014-52 reminding U.S. citizens and resident aliens, including those with dual citizenship who have lived or worked…
Should I close my foreign account?
…the little untidiness. Foreign accounts and assets are being scrutinized by the IRS and FinCEN (the Treasury Department subdivision that reviews FBARs). The stakes are high, with huge civil penalties…
2012 Offshore Account Criminal Tax Cases
…be Wegelin) which began actively recruiting U.S. customers in 2008 after another bank, UBS AG, lost U.S. accounts due to an IRS investigation and eventual litigation. United States v….
New Streamlined Domestic Offshore Procedures (SDOP) is a Game Changer
The IRS has announced a Streamlined Domestic Offshore Procedures (SDOP), which will significantly alter all future voluntary disclosures. The SDOP is a game changer for residents and non-resident (who would…