Search Results for: irs appeal
Payment Apps like Venmo and Paypal Now Subject to Tax Reporting
…Plan Act (ARPA), third-party peer-to-peer cash apps must begin reporting to the IRS business transactions totaling $600 or more. The new law aims to clamp down on business people, particularly…
10 Most Frequently Asked Questions and Answers for Stretch IRAs
…private letter ruling by the IRS, you can avoid immediate liquidation and extend the life of the IRA because beneficiaries are now allowed to make the required distributions from the…
What Is The Difference Between the SDOP and the Current OVDP program?: Willfulness
…knowledge and violations. Although filing an SDOP does not automatically select the taxpayer for an IRS audit, the taxpayers is still subject to the possible normal audit selection. The taxpayer…
Tax preparer sentenced to prison for fraudulent deductions on federal income tax returns
…late 2016 an analyst with the IRS noted that an unusually large number of returns prepared by Mpouli claimed deductions for unreimbursed business expenses. In 2017, the IRS Criminal Investigation…
Pandora’s Box Has Opened: Pandora Papers
…you can expect in the coming months that many new names will come out that the IRS will be interested in targeting. Filing Requirements If You Have Foreign Accounts By…
A great time for GRATs
…a term of years. The income interest will be equal to the Internal Revenue Service (“IRS”) Section 7520 rate in effect as of the date of funding. This rate is…
Maryland Retail Store Owner Guilty of Tax Fraud and Tax Evasion
…salary at Company 1, resulting in a tax loss of $70,000 to the IRS. Chawla and Saurabh discussed and agreed on the amounts that Chawla would list on his tax…
Offshore Voluntary Disclosure Initiative/Program (OVDI/OVDP) opt-out results and updates
…OVDP program continues the procedures announced in 2011 regarding decisions to “opt out” of the voluntary disclosure penalty structure. In such a case, IRS agents are instructed to neither punish…
US Department of Justice Encourages Swiss banks to Disclose Information
…Fla., was convicted by a jury in Fort Myers, Fla., of conspiring to defraud the IRS and of filing false individual income tax returns. According to evidence presented at trial,…
Start 2021 with a few New Year’s tax planning resolutions
…generation. Update your W-4 Form. The IRS revised the W-4 form in 2019 to make it easier for workers to calculate the correct withholding, but many employees have not yet…
Another U.S. taxpayer with an offshore HSBC bank account pleads guilty
…of three years in prison and a maximum fine of $250,000, or twice the amount of financial gain to the defendant or loss to the Internal Revenue Service (IRS). Additionally,…
Accountant-Client vs Attorney-Client Confidentiality
…practice before the IRS. Furthermore, the confidentiality does not apply to criminal proceedings, documents needed to prepare a tax return, or communications regarding tax shelters. For example, if you are…
Significant FBAR Penalties Upheld by Court
…the IRS on her tax return and on Foreign Bank Account Report (FBAR) forms. In 2009, when the IRS introduced its Offshore Voluntary Disclosure Program (OVDP), she joined the program…
Naming A Minor as Your IRA Beneficiary
…Jack born the year you die. Jack’s life expectancy at age 1, according to the IRS life-expectancy table for inherited IRAs is 81.6 years. Jack could stretch the minimum required…
Watch Out for Letters From Your Foreign Bank Requesting Information On Your U.S. Residency
…banks abroad. The bank letters generally inform the customer that the account information may be disclosed to the IRS as necessary under FATCA and advising the customer to discuss their…
Adding Beneficiaries to an Irrevocable Life Insurance Trust
…should the beneficiary predecease the grantor. However the use of contingent beneficiaries may prompt the IRS to audit and litigate. A more conservative approach is to follow the IRS rulings:…
A Lesson From Brown v. U.S.: A Defective Tax Refund Filing
…that the Browns’ claims did not meet the requirements for a claim to be “duly filed.” Subsequently, the Browns timely appealed to the U.S. Court of Appeals. Court’s Ruling and…
2008 Year End Estate and Trust Taxes and Planning: Before It’s Too Late!
…FLPs. These challenges have culminated in a series of successful court cases for the IRS. The IRS has had success in cases where the facts indicate, among other things, that…
U.S. Tax Court: What to Expect
…still receive a notice of deficiency or notice of determination that you believe is wrong. You have undergone a collection due process hearing and disagree that the appeals officer took…
Watch Out for PFIC Status
If you invest internationally a Passive Foreign Investment Company (PFIC) could be a nightmare that could become a reality if you happen to invest in what the IRS deems a…
Structuring: A Tax Crime
One of the most frequent criminal charges our firm encounters is the illegal structuring of cash transactions to evade the IRS reporting requirements of Section 6050I. Usually the taxpayers who…
Educational Panel Discussion: The U.S. Government’s Global Crackdown on Tax Evasion: Where It Has Been and Where It Is Going
…described in detail the IRS expansive network of IRS global operations in dozens of countries. We discussed in detail the Offshore Voluntary Disclosure Program (OVDP), which is specifically designed for…
New Much-Needed Guidance for Non-Willful FBAR violations
…in FBAR case file information. We find that the guidance is much needed in light of the lack of uniformity in the IRS’ application of FBAR non-willful penalties. The memo…
Tax treaty tie-breakers
…result. It is important to note that tax treaty benefits do not provide an exemption from filing of most information returns such as IRS Form 8938 or FBARs. To take…
New guidance on fixing a botched IRA stretch after it’s “too late”
…50% excise penalty for the insufficient RMDs for 2003 and 2004, but in return the IRS allowed the beneficiary to subsequently continue RMDs based on the beneficiary’s life expectancy, preserving…
New offshore voluntary disclosure program (OVDP) changes expected to be favorable to taxpayers
During Internal Revenue Service (IRS) Commissioner John Koskinen’s remarks at a speech before the United States Council-OECD International Tax Conference in Washington last week, he indicated that the agency is…
New EZPASS OVDP Without Any Penalties for Non-Resident U.S. Taxpayers
Yesterday, as expected, the IRS announced its new New Filing Compliance Procedures for Non-Resident U.S. Taxpayers that taxpayers presenting “low compliance risk” should file delinquent tax returns, including delinquent information…
Opting-out of the Offshore Voluntary Disclosure Initiative: FBAR Penalty Mitigation Guidelines
…those who do not know about the Normal FBAR Penalty Mitigation, you should see http://www.irs.gov/irm/part4/irm_04-026-016.html#d0e1317. The Normal FBAR Penalty Mitigation are also provided below. Normal FBAR Penalty Mitigation Guidelines for…
Foreign Account Tax Compliance Act – Traps for the Unwary
…to report their assets to the IRS. Under the FATCA, there’s an up-to-$50,000 penalty for failing to file with your return the new 6038D statement disclosing specified foreign financial assets…
US passport and green-card has lost its glamour
A US passport or green-card is losing its glamour and appeal. Some people are surrendering their prized green cards because of the US Foreign Account Tax Compliance Act (FATCA), which…