Search Results for: 3520 penalties
IRS Criminal Investigation Division Summonses: A Key Tool in Tax Crime Investigations
…an explanation of the objection procedure. Requirements for Summoned Individuals Individuals served with a summons must preserve all relevant records and documents. Failure to comply can lead to penalties. If…
Form 3520: A Comprehensive Guide to Navigating the Complexities of Foreign Gift Reporting Under the Latest 2024 Proposed Regulations
…3520 plays a crucial role in ensuring the proper reporting of substantial foreign gifts. While primarily an informational return, non-compliance with its filing requirements can lead to severe financial penalties,…
Detailed Technical Comments and Recommendations to the IRS on Proposed Regulations for Form 3520 and Code Section 6039F (REG-108066-22)
…information available to different taxpayers. 4. Penalties for Non-Compliance: Promoting Fairness and Encouraging Voluntary Compliance Under Proposed Treas. Reg. § 1.6039F-4 The existing penalties for late or inaccurate filing of…
IRS Issues New Proposed Regs on Information Reporting on Foreign Gifts
…complete Part IV of Form 3520 to report the receipt of more than $100,000 from a foreign individual. Taxpayers who miss the Form 3520 filing deadline may be subject to…
Form 5471 Penalties Upheld in Latest Court Ruling
…structure, and function of section 6038 indirectly support the IRS’s assessment authority for those penalties. “It is hardly anomalous that section 6038(b) penalties are assessable even though the text of…
NJCPA Seminar “The Corporate Transparency Act: What You Need To Know”
…are the penalties for noncompliance? What steps should one take to comply? What’s next? Experienced tax attorney Parag Patel has handled hundreds of complex tax matters for clients. The New…
IRS Guidance Targets Cash Reporting in the Cannabis Industry
…Non-Compliance Failure to correctly file Form 8300 can lead to substantial penalties, especially if the IRS determines the noncompliance was intentional. Historically, the IRS has prioritized compliance over using penalties…
IRS International Fines Not Excessive: Form 3520 Penalties Upheld, Form 5471 Penalties Again Unassessable
…3520, and 3520-A) relating to foreign accounts. The Tax Court largely rejected the taxpayer’s constitutional challenges but did find that the IRS could not automatically assess Form 5471 penalties, a…
Questionable ERC could mean trouble for CPAs
…their clients of the option to file an amended return, as well as penalties for noncompliance. In short, Section 10.22(a) cited in the guidance binds accountants to diligence as to…
Employers Must Re-examine Employee Retention Credit (ERC) Claims
…improper claims. Options for Employers with Incorrect Claims ERC Voluntary Disclosure Program (Deadline was March 22, 2024; may be extended): Repay 80% of the incorrect ERC, with reduced penalties and…
IRS Enforcement Campaign Targets High-Income Non-Filers
…2017 through 2021. The IRS expects this initiative to yield significant recovery of unpaid taxes, along with associated penalties and interest. This effort aligns with the IRS’ broader focus on…
Is First-Time Abatement Applicable In International Penalty Cases?
…also known as IRM, specifically IRM 8.11.5, Penalties Worked in Appeals, International Penalties. According to the IRM code, FTA waivers are generally not provided or applicable to international penalty cases….