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ERC Disallowance Letters 105C Sent to Taxpayers
…between March 13, 2020, and Dec. 31, 2021. Entities established after Dec. 31, 2021, are not entitled to the ERC under the law passed by Congress. There are no paid…
Rare Supreme Court Ruling Favors Taxpayers!
…that the penalty could be imposed per unreported account (Bittner, 19 F.4th 734 (5th Cir. 2021)); the Ninth Circuit has held it can only be applied per unfiled FBAR covering…
New IRS procedures for Streamlined Filing Compliance Procedures for 2017 transition tax filers
…2020, 2021, and the additional 2017 year. Note: The election to pay net tax liability in installments under section 965(h)(1) is not available for taxpayers submitting delinquent returns under the…
Malta Pension Plan Being Investigated by IRS Criminal Investigation Division
…and that it was not intended by the Treaty drafters. History: In July 2021, the IRS added the Malta Pension Plan to its “Dirty Dozen” list of abusive tax schemes….
Watch Out: Malta Pension Plans Become Listed Transaction
…underpayment of tax attributable to the listed transaction, plus $10,000. The IRS previously placed Malta personal retirement schemes on its “Dirty Dozen” list in July 2021. According to the IRS,…
Smart Planning for Expected Capital Gains Tax Increases
…future years. High-income taxpayers should explore installment sale to defer capital gains. Installment Sale An installment sale under Code Section 453 involves a sale of property where at least one…
Malta pension plans listed on “Dirty Dozen” list of “tax scams”
…that it is evaluating the validity of such arrangements and may challenge the tax treatment of Maltese pension plan contributions and distributions. IR-2021-144 (July 1, 2021). The types of pension…
Canceled Debt: Taxable or Not
During the pandemic many clients’ businesses have adversely impacted by lockdowns and many negotiations between borrowers and lenders have occurred or will occur in 2021. There will be many loan…
Client Case Study: Tax Savings Now
…million in 2021. Further, the estate tax exemption remains $1 million at Jay and Maya’s death and current estate tax rates (about 40%) remain the same. SLAT in Action Because…
Watered-Down Build Back Better (BBB) For High-Income Taxpayers
…evolve in the Senate. DRAFT Build Back Better Act in September 2021 Build Back Better Act, as passed by the House in November 2021 Individual income tax rates Raise…
FBAR Reporting Season is here
…years) and is only available online through the BSA E-filing system website. A link to the BSA E-filing system is attached: http://bsaefiling.fincen.treas.gov/main.html And a link to Form 114a follows:…
Cayman Islands Advisors Arrest Suggest U.S. Government Receiving More Information About Offshore Accounts
…clients. Clients were able to monitor their investments online through the use of anonymous, numeric passcodes. Upon request from the U.S. client, Vandyk and St-Cyr would liquidate investments and transfer…
IRS Reminds (again) Taxpayers to Report Foreign Income and Assets
…past. It is due to the Treasury Department by June 30, 2014, must be filed electronically and is only available online through the BSA E-Filing System website. For details regarding…
Complicated Form 5471 filing requirements simplified for dormant foreign corporations
…further questions about your reporting requirements on this, or any other offshore reporting form, contact us online to schedule a free confidential strategy session consultation. Patel Law Offices has consulted…
The New DIIRSP: I like the old better
…(which have since been taken down online) confirmed this in stating “Taxpayers who have unreported income or unpaid tax are not precluded from filing delinquent international information returns.” Therefore, a…
New IRS Disclosure Program Announced for Non-Resident Taxpayers: Streamlined Foreign Offshore Procedures
…deferral is permitted by an applicable treaty (this generally applies to Canadian retirement accounts, i.e., RRSPs). – A statement that six years of FBARs are being filed online via the…
IRS Announces Major New changes to the Offshore Voluntary Disclosure Program
…go fully online, the cost (and risk) of doing nothing seems to have gone up significantly. Our firm presented an informational webinar on the Streamlined Filing Compliance Procedures. Materials from…
Internal Revenue Service announces new International Data Exchange Service: The Beginning of Information Sharing
…will initiate enrollment online on their own; in order to enroll, the financial institution will need to have registered as a participating financial institution through the IRS FATCA Registration System…
50% Penalty for Taxpayers Who Hold Accounts at a Bank Under Investigation
…Regardless, as FATCA continues to go fully online (and the bank list grows), the cost and risk of doing nothing seems to have gone up significantly. In summary, taxpayers with…
IRS’ New “Dirty Dozen” list of tax scams
…OICs submitted to the IRS. The agency accepted 18,000 of them. Individual taxpayers can use the free online Offer in Compromise Pre-Qualifier tool to see if they qualify. The simple…
PRESIDENT BUSH SIGNS THE HOUSING AND ECONOMIC RECOVERY ACT OF 2008 WITH TAX BENEFITS AND TRAPS FOR THE UNWARY
…2008 tax return and get the refund a year early. Unlike other credits, however, the first-time homebuyer credit must be repaid in equal installments over 15 years, essentially making it…
President Trump Revamps the IRS through his 2019 Taxpayer First Act
…within one year. The plan is to provide reasonable taxpayer services for online service, telephone callback services, and employee customer service training. IRS guidance and training materials must be updated…
Expect new aggressive IRS targeted enforcement next year.
…fact, I recommend taxpayers get independent tax legal counsel to review complex tax returns (beyond the regular tax preparer). To schedule a free tax planning strategy session book an appointment online….
The Taxpaper Roadmap (seriously?)
…repetitions between stages. You can view it online or, if you want your very own 18″ x 18″ poster that’s suitable for framing, call 800-829-3676 and request Publication 5341. U.S….
New IRS guidance Announced for IRS Streamlined Offshore Procedures.
…Regardless, as FATCA continues to go fully online (and the cooperating bank list grows), the cost and risk of doing nothing has gone up exponentially. In summary, taxpayers with undisclosed…
New IRS Voluntary Disclosure Program lets employers who received questionable Employee Retention Credits pay them back
…and prosecute advisors in other contexts. ERCVDP submissions are submitted through an online document upload, which is entirely different from past IRS voluntary disclosure programs that required paper filing. This…
The New IRS ERC Voluntary Disclosure Program
…Employers who cannot repay 80% of the credit may be considered for an installment agreement on a case-by-case basis, pending submission and review of Form 433-B. The IRS will not…
IRS announces new Streamlined Filing Compliance Procedures
…determine the most advantageous route in light of these new rules. As FATCA continues to go fully online, the cost and risk of doing nothing seems to have gone up…
A solution in a tough tax season: the IRS Streamlined Offshore Procedures
…the risk/reward for each taxpayer. Regardless, as FATCA continues to go fully online (and the cooperating bank list grows), the cost and risk of doing nothing has gone up exponentially….
IRS list of “dirty dozen” tax scams
…tactic used by scam artists to trick unsuspecting victims into revealing personal or financial information online. Phishing involves the use of phony e-mail or websites — even social media. A…