Search Results for: irs appeal
2020 New Year’s Tax Planning Resolutions: Resolve To Plan Better
…foreign accounts. The IRS has publicly stated that foreign accounts tax compliance is a priority in enforcement. In 2019, the IRS announced that it began mailing warning letters to certain…
Reasonable Cause Defense Denied: FBAR Penalties Assessed by Court
…is bank that was heavily scrutinized by the IRS). Agrawal used money from CDs in India that were maturing to fund the UBS account. Agrawal directed UBS to invest the…
US Taxation of Foreign trusts: Foreign grantor trust
…U.S. Person Beneficiary need only report the distribution from the FGT to the Internal Revenue Service (the “IRS”). Option 2 (Irrevocable Trust): The U.S. Person beneficiary may not directly benefit…
US Entities with foreign assets have more information reporting
The US Treasury has issued long-awaited regulations specifying the domestic taxpayers who have to disclose substantial foreign financial assets to the Internal Revenue Service (IRS) every year. The new rules,…
Passive Foreign Investment Company Tax & Mark-to-Market (MTM) election
…often results in frequent distributions. How does an individual report to the IRS under the PFIC regime? In general, an owner of a PFIC must file a four-page Form 8621…
Another Local New Jersey client of HSBC India Pleads Guilty
…his gain from the offense, together with the costs of prosecution. Gupta agreed to file true and accurate tax returns and to pay to the IRS all taxes and penalties…
Post-Covid: Re-explore the Home Office deduction
…use. Self-employed taxpayers filing IRS Schedule C, Profit or Loss from Business (Sole Proprietorship) first figure this deduction on Form 8829, Expenses for Business Use of Your Home. The IRS introduced a Simplified…
To Gift or Not to Gift? Gift.
…Wealthy people are especially nervous that an exemption allowing individuals to leave up to $11.58 million to heirs, free of estate or gift taxes, could soon be cut before it…
Another Taxpayer Found Guilty of Failure to File FBARs and Report Foreign Income
Raju Mukhi of St. Louis MO was indicted last year for his alleged failure to file a report to the IRS on his foreign financial accounts and for filing false…
India and the US have agreed to collaborate on offshore tax evasion
…required to report tax information about US account holders directly to the Indian government which will, in turn, relay that information to the IRS. Under FATCA, financial institutions, including banks,…
Dormant foreign corporations not subject to complicated Form 5471 filing requirements
The reporting requirements for IRS Form 5471 are complex, including ‘category of filer’ and required schedules. However, very few taxpayers know that there are special simplified filing rules for a…
Parag Patel Esq. Speaks at Annual Convention of New Jersey Society of Certified Public Accountants
…Description: Hot Topics in Tax Controversy With new funding, the IRS has ramped up enforcement, and all tax professionals must be familiar with the latest strategies in audit and tax…
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…
Charitable Remainder Trust: Frequently Asked Questions
…income can be paid over your life, your spouse’s life and even your children’s and grandchildren’s lives. 2. What section of the IRS code governs whether a trust qualifies as…
Taking Advantage of Low Interest Rates
…rate” under Internal Revenue Code §7520. AFRs are calculated and published by the IRS every month and represent the minimum rates of interest that must be charged on debt instruments…
Estate Planning in a Recession
…investing, business start-up, education, home purchase, and other purposes. The IRS sets minimum interest rates for these types of loans, well below bank rates, depending on the maturity date. Lower…
Difference between Form 8938 and FBAR Requirements
…with income tax return pursuant to instructions for filing the return Mail to: Department of the Treasury Post Office Box 32621 Detroit, MI 48232-0621 For express mail to: IRS Enterprise…
Year-End Checklist for 2009
…most effective when the value of the residence to be given is low and the IRS assumed rate of return is high. However, even though the IRS assumed rate of…
2011 Offshore Voluntary Disclosure Initiative Frequently Asked Questions (FAQs) and Answers
…step for a taxpayer making an offshore voluntary disclosure is the submission of the Offshore Voluntary Disclosures Letter. This letter will be reviewed by IRS Criminal Investigation (CI), and taxpayers…
The InSECURITY of the SECURE Act
…distribution (RMD) rules allowed a nonspouse beneficiary to gradually drain inherited IRAs over the beneficiary’s IRS-defined life expectancy. For example, Sally is 40 years old when she inherits her elderly…
Navigating Foreign Waters: The Complex Requirements of Foreign Accounts Compliance
…21, 2011 – 7:00 p.m. to 10:00 p.m. Navigating Foreign Waters: The Complex Requirements of Foreign Accounts Compliance Parag P. Patel, Esq. With the IRS aggressively targeting taxpayers with unreported…
From Hong Kong With Love…
…by the IRS. See Regs. §1.679-4(d), IRS Notice 97-34, §V(A). In summary, transfers received from Hong Kong due to the local political instability and held in the US person’s account…
NJ Contractor Charged with Criminal Tax Evasion for Unreported Checks
…2016 and 2017, Konopka failed to file any corporate returns as required. From 2014 through 2017, Konopka caused no payments to be made to the IRS for any corporate tax….
Pointers on the Yearly Gift Tax Exemption
…the gift does not have to pay the tax The exemptions for gifts and the gift tax rates are established by the IRS. In 2009 the gift tax exemption threshold…
Another Foreign Bank Charged by U.S. Department of Justice
…or Frazzetto to hide their accounts. About 30,000 U.S. taxpayers have avoided prosecution since 2009 by voluntarily disclosing offshore accounts to the IRS. The Justice Department has interviewed many of…
US DOJ Tax Asst Attorney General Keneally Reports that One third of Swiss Banks Joining US DOJ Swiss Bank Program
We have previously posted on the U.S. Justice Department’s program offered to Swiss banks and targeted to identifying U.S. taxpayers that have not disclosed foreign accounts to the IRS. It…
Wash Sale Benefits for Cryto Investors
…IRS and is currently not subject to the wash sale rule. An investor in a virtual currency can sell their position to lock in a capital loss and immediately repurchase…
High Penalties for failure to file an FBAR: Not Really Enforced (yet)?
…failed to file an FBAR, you should still file it as soon as possible. The IRS will not impose a penalty for the failure to file a delinquent FBAR if…
Navigating the Step-Up Tax Basis Rule
…including retirement plans, IRAs, joint property and life insurance proceeds. If mom or dad’s taxable estate is above the IRS exemption amount, all of the amounts in excess of that…
The Taxpaper Roadmap (seriously?)
The Taxpaper Roadmap was recently created by The Taxpayer Advocate Service, an independent organization within the IRS. This map illustrates, at a very high level, the stages of a taxpayer’s…