Search Results for: irs appeal
FBAR Reporting Season is here
…file foreign financial account reports during the current period, please note the updated information related to reports regarding foreign financial accounts which is set forth on the IRS website: http://www.irs.gov/Businesses/Small-Businesses-&-Self-Employed/Report-of-Foreign-Bank-and-Financial-Accounts-FBAR…
New FBAR Deadlines and Penalty Relief available
…or signature authority (as defined) over a foreign bank, brokerage or other financial account during a calendar year must report it to FinCEN (not the IRS) electronically using the BSA…
Do Inherited Foreign Assets Receive a Step-up in Cost Basis for U.S. Tax Purposes?
…IRS states through various revenue rulings that foreign property is entitled to a step-up in its basis. Section 1014(b)(1) of the U.S. tax code adds that inherited property is deemed…
Asset Protection for Physicians
…all this sounds neat, the IRS considers it to be an abusive tax shelter, and the U.S. Department of Justice has started prosecuting those who have participated in these schemes….
Parag Patel Esq. speaks at New Jersey Society of Certified Public Accountants (NJCPA) Annual Tax Seminar: “2022 Federal Tax Update and Latest Tax Controversy Hot Topics”.
…on November 18, 2022. Seminar Summary: With the pandemic fading and new funding, the IRS has ramped up enforcement and tax professionals must be familiar with the latest developments in…
Complicated Form 5471 filing requirements simplified for dormant foreign corporations
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 NJCPA Seminar on”Criminal Tax: What Tax Professionals Need to Know to Help Clients and Themselves”
…to Help Clients and Themselves” Seminar descriptions is below: “Criminal Tax: What Tax Professionals Need to Know to Help Clients and Themselves” . The IRS is devoting significant new resources…
Opting Out of the OVDI Program: Argue for No Penalty and a Warning Letter
The revised IRS OVDP FAQs offer helpful guidance on the opt-out option. The newly revised FAQs illustrate the pros and cons of opting out with examples. Depending on the circumstances,…
Parag Patel Esq. speaks at NJCPA Seminar ” Federal Tax Update and Latest Tax Controversy Hot Topics”
…Hot Topics“. Seminar descriptions is below: Federal Tax Update and Latest Tax Controversy Hot Topics With new funding, the IRS has ramped up enforcement, and tax professionals must be familiar…
FATCA Noncompliant Accounts may be Frozen or Blocked
…shared with the IRS. If the US account holder has not properly reported the existence of the account and income earned on the account on US tax returns then significant…
THE ABCs OF STRETCH IRAs
…know something of the rules and regulations governing stretch IRAs, look for an advisor with an advanced education in IRA planning. Citations. 1 investmentnews.com/apps/pbcs.dll/article?AID=/20080501/REG/74256949/1031/RETIREMENT 2 kiplinger.com/retirementreport/features/archives/2006/06/Cover_Jun2006_03_01.html 3 irs.gov/pub/irs-pdf/p590.pdf 4 moneycentral.msn.com/content/Taxes/Taxshelters/P33760….
Administrator of a Probate Estate: Duties and Responsibilities
…returns and other tax documents having to do with the estate. The administrator should also file a written notice with the IRS that he or she is serving as the…
Owner of Iberia Restaurants in Newark Found Guilty of Tax Crimes
The failure to file and pay payroll taxes has been a major focus of IRS investigations in the past few years. Sometimes the cases are civilly examined, but occasionally the…
Leave Your IRA to a Special Needs Trust
In a private letter ruling recently, the IRS addressed the issue of transferring an inherited IRA into a Special Needs Trust. The law around taxation of inherited IRAs and the…
Businesses Owners Need To Plan for Their Exit: Companies should be prepared for the boss’s departure
…of the shares,” Patel says. That “avoids valuation disputes with the IRS, which may otherwise value the business higher and seek more on taxes after it is sold.” A way…
How Long is the Tax Fraud Statute of Limitations?
…indefinite or unlimited fraud statute refers to civil tax fraud, not criminal tax matters. The IRS basically has unlimited time to audit you for civil fraud. But due to the…
Taxpayers’ Evidence of Non-Willfulness or Willfulness Factors
…is really non-willful. Unfortunately, the IRS has publicly stated that it will intentionally give no further definition of non-willful conduct for purposes of the Streamline Compliance Programs (SFOP or the…
Keeping Tax Papers
…1099 forms, and receipts and canceled checks for deductible items, for at least three years after you file. In general, the IRS has up to three years after you file…
Taxation of Employment-related Discrimination Claims
…desirable settlement characterization for tax purposes, and even if they are, they may not be able to properly characterize the settlement to pass IRS scrutiny. One problematic characterization for many…
New FBAR FIling Deadline Law Signed
…15th, if this is the first time the FBAR was due. High penalties apply for failure to file FBARs. However, the IRS already has discretion to waive FBAR filing penalties….
Beware of Overlooked Common Overseas Tax Forms
…your preparer is qualified to do the work. Many of these forms are quite complex and require special training to prepare. The IRS, for example, estimates that each Form 8621…
Streamlined Procedures for U.S. Taxpayers Residing In the United States
Many of our clients are interested in the new Streamlined Filing Compliance Procedures, which were recently announced by the IRS. Therefore, we are providing more general information on the Procedures….
Estate Planning When a Spouse is Confronting Health Issues (Estate Planning for the Healthy Spouse)
…1996), appeal denied, 659 N.Y.S. 2d 854 (1997). This legislation imposes a 36-month “look-back period,” in which Medicaid officials will “look back” from the application date to analyze asset transfers…
Estate Tax Pitfalls Seen In Court Case
…court held the estate, not Schleis, responsible for the tax and last week the state’s highest court affirmed that ruling after an appeal. All of the trouble could have been…
A Lesson to be Learned from US v. Schwarzbaum: Bring Back the Foreign Funds to Pay FBAR Penalties
…penalties and interest, which totalled over $18 million in penalties. Following this order, Schwarzbaum appealed to the 11th Circuit where it remained pending when the federal district court issued its…
NJ Division of Taxation Announces Conferences and Appeals Branch Initiative
…reached, a Final Determination will be issued and the taxpayer may then exercise their further appeal rights. Ensuring that the Branch has updated information for telephone and e-mail contacts for…
Republican Party Rallies Against FATCA: Success Unlikely
…be the party’s first appeal to scrap the law -the Foreign Account Tax Compliance Act (FATCA) – a panel was slated to vote at the Republican National Committee’s (RNC) winter…
New Jersey Division of Taxation Now Issuing Letter Rulings
…that the Division may contact for questions regarding the request or for redaction confirmation •Disclose any ongoing New Jersey tax matter, such as audit, refund or appeal with the Division’s…
Is HSBC the next UBS nightmare?
…to require the bank to disclose the names of as many as 52,000 wealthy American clients. UBS disclosed secret data to the IRS on more than 4,000 accounts. That prompted…
What is an Irrevocable Life Insurance Trust (ILIT)?
…IRS and, if applicable, state taxing authorities, can then tax the proceeds at death. How an Irrevocable Life Insurance Trust Works: One way to avoid the taxing of life insurance…