Search Results for: irs appeal
PRESIDENT BUSH SIGNS THE HOUSING AND ECONOMIC RECOVERY ACT OF 2008 WITH TAX BENEFITS AND TRAPS FOR THE UNWARY
…returns just to pay the credit back. You can expect IRS computers to track this and to issue notices for unfiled returns. If you sell the house in less than…
Vatican Signs FATCA Agreement
…100 countries will be providing government help to the IRS means that no foreign account is secret. U.S. persons must report worldwide income and most must file IRS Form 8938…
New Court Case Limits the Reasonable cause exception to FBAR penalties
…in the U.S. Court of Federal Claims suggests that CPA advice may not be enough to stop the IRS from assessing FBAR penalties for non-willful reporting violations. Background: Who Must…
Penalties for Not Filing Form 3520
…penalty, they should submit a written request to appeal within 30 days from the date of the notice explaining the reasonable cause for failure to report. This appeal should include…
Information Sharing of Account Holder Information Officially Begins
…also receive information from the US regarding their taxpayers with U.S. accounts. According to IRS pronouncements, the IRS has said that the following 34 countries, including most developed countries, have…
FBARs from Wuhan
…return and two counts of failing to file reports of foreign bank and financial accounts (FBAR) with the Internal Revenue Service (IRS). The indictment alleges that Lieber served as the…
New Leak of Offshore Accountholders Highlights the Need to Clean Up
…IRS Streamlined program for non-willful violations is far simpler and much less costly. The Streamlined programs came with the 2014 improvements to the OVDP, which sparked and renewed interest in…
Common Issues for US-India Tax Reporting
…your risks. Account holders MUST be certain they are in full compliance with all United States reporting requirements to avoid future tax and legal problems. The IRS has established several…
How to Benefit from Tax Treaties
…to help alleviate that concern. IRS Form 8833 is how you would claim and report certain U.S. income tax treaty benefits, which can include anything from lower tax rates to…
US Court finds non-willful FBAR penalty not limited to $10,000 per year
…generally due April 15, but that date is most commonly extended to Oct. 15 each year. Under 31 U.S.C. 5314, the IRS is directed to require a resident or citizen…
Happy Birthday Streamlined Filing Compliance Procedure
The Streamlined Filing Compliance Procedure (SFCP) was “born” six years ago. Six years ago the IRS publicly announced the SFCP, which has been used by many non-compliant US taxpayers with…
US Reporting of Foreign Retirement Accounts
Many clients contact our office regarding the failure to report their foreign retirement account. Such accounts need to be fully reported on an FinCen 114 (FBAR) and IRS Form 8938….
BUSINESS SUCCESSION LEGAL PLANNING
…to the IRS with respect to estate and gift taxes. One way to deal with this problem is gifting. With a new IRS ruling allowing for gifts of minority shares…
Swiss Government and US Government Announce New Program for Cooperation and Disclosure by Swiss Banks
…US persons. (Please see our reports on these developments, listed below.) With the knowledge that the IRS and the DOJ through their ongoing investigations into tax evasion have already uncovered…
Another foreign bank customer found guilty of foreign income under-reporting and FBAR violations.
…maintained in India and in Bailiwick of Jersey, France, the Justice Department and Internal Revenue Service (IRS) said. Ahuja managed his offshore accounts with the assistance of bankers who worked…
New FBAR Deadline applies to 2016 Tax Year Onwards
…IRS Form 4868 or IRS Form 7004 to incorporate the FBAR. The Act is effective for tax years beginning after December 31, 2015, so the new filing deadlines will not…
Income Taxation of FMLA Claims
…tax. If part of your FMLA award includes interest, punitive damages or compensation for mental anguish, the IRS still requires you to include those amounts in taxable income. Division of…
To Opt Out or Not Opt Out: That is the Question
…returns showing the income regarding the offshore accounts, and let the IRS decide whether to impose the statutory FBAR penalties. As per the IRS FAQs website, “Taxpayers who have already…
Details of the Delinquent International Information Return Submission Procedures (DIIRSP)
…Statement of Specified Foreign Financial Assets No penalties are applied if there is reasonable cause for the failure to file the information form and the IRS agrees. Reasonable Cause is…
The legal standard of “willfulness”: Opt out to avoid high penalties
Under IRS Form 1040, at the bottom of Schedule B, Part III, on Page 2, Question 7(a) states: “at any time during the previous year, did you have any interest…
Form 8938, FATCA, FBAR and penalties for all (including bankers)
The IRS and US Treasury have stepped up their efforts toward tracking down delinquent tax payers and enforcing payment of overdue taxes. One of these initiatives is the “Foreign Account…
India issues FATCA Self-certifications and KYC Warnings
…Over 100 countries have signed on to FATCA and automatically report foreign account and income data to the US IRS. As a result, foreign banking secrecy no longer exists: virtually…
New Jersey Tax Amnesty program
…an administrative or judicial appeal related to a tax assessment, you may participate in amnesty only if you withdraw your appeal, waive all rights to a future appeal and receive…
New Court Ruling: FBAR penalties applied per form and not per account
…years until May 2012. In June 2017, the IRS assessed penalties against Bittner for “non-willful” FBAR violations. The government filed a motion for partial summary judgment seeking $1.77 million in…
A limited opportunity for generous gift tax exclusions
…for the benefit of her husband and children. The trusts cannot be identical in form, as the IRS has held that if two individuals create identical trusts for each other,…
The FinCEN Files Leak
…to generate an SAR. In a recent IRS internal memo dated March 15, 2012, the IRS pointed out to its agents in the Small Business Self-Employed Division (SBSE) that SARs…
Caution: Increased FBAR Enforcement
…years the Bernsteins had foreign accounts and did not file FBARs, answered “no” on the IRS Form 1040 Schedule B Part III foreign account signatory interest question, and did not…
First Indictment for FATCA Violation Announced
…those bogus profits. Laundered approximately $500 million US in criminal proceeds. “The investigation of offshore tax evasion and money laundering are top priorities for IRS-Criminal Investigation, and we are committed…
Swiss Banks are Pressuring Customers to Disclose
…prove they have declared the account to the IRS—or that they are trying to enter the agency’s limited-amnesty program for U.S. taxpayers with secret accounts. In addition, many Swiss banks…
AICPA Makes Useful Recommendations For International Forms 3520/3520
The American Institute of CPAs (AICPA) submitted comment letters to the IRS requesting improvements be made to two international tax returns pertaining to foreign trusts. The AICPA requested that the…