Search Results for: audit
Appeals of penalties imposed during the Offshore Voluntary Opt-Out
…there any appeal available to contest an OVDI opt-out penalty? Yes. Opt outs are essentially audits, and audit determinations can be appealed in the same manner as lesser court rulings,…
IRS Announces Penalty Mitigation for Smaller US Taxpayers Living Abroad
…the past six years. Submissions from taxpayers that present higher compliance risk will be subject to a more thorough review and potentially subject to an audit, which could cover more…
IRS announces two new intriguing targeted enforcement campaigns
…campaigns, the failure to respond to such letters may result in audit or penalties and possible criminal prosecution. As a result, we expect increased IRS audit activity for clients with…
The Dreaded IRS Letter 6185: “We received information that you have a foreign account”
…Failure to respond to such letters may result in audit or penalties and possible criminal prosecution. However, prior to audit, taxpayers can still become compliant by entering one of the…
IRS delinquent FBAR submission procedure
…FBARs will not be automatically subject to audit but may be selected for audit through the existing audit selection processes that are in place for any tax or information returns….
The IRS Large Business and International division (LB&I) has announced a new Post OVDP Compliance enforcement campaign
…offshore private banks. This campaign indicates the IRS’ renewed focus on OVDP and taxpayers’ foreign activities. The IRS will initially address tax noncompliance through audit examination and soft letter treatment…
Beware IRS Letter 6291
…targeted taxpayers identifying tax noncompliance and passively seeking compliance. Failure to respond to such letters may result in audit or penalties and possible criminal prosecution. However, prior to audit, taxpayers…
2 recent IRS developments that will impact Indian Americans
…an option. “The filing of an amended income tax return has heighted audit risk (probably significantly greater than the original filed return). The filing of a delinquent FBAR also has…
IRS Announces New Statistics Regarding Voluntary Disclosures
…subject to IRS audit automatically, the IRS points out that: “[t]hey may be selected for audit under existing audit selection processes applicable to any U.S. tax return and may also…
Substantially Completed Form 5471 is Required to be Filed
…insight as to how IRS examiners may audit a particular issue or transaction. However, they are not official pronouncements of law or directives and cannot be used, cited, or relied…
Demystifying IRS Agents
…taxpayers. In my decades of experience as a tax attorney defending taxpayers on complex tax examinations (e.g., audits), I found IRS Agents to be normal people just like you and…
Denied access to or withdrew from the IRS Offshore Voluntary Disclosure Program (OVDP)?
…Accounts (FBARs). Submissions under Option #2 may result in the IRS proposing penalties and/or conducting an audit. Option #3 allows taxpayers who believe they are already fully compliant to submit…
Happy Birthday Streamlined Filing Compliance Procedure
…taxpayer for an IRS audit, the taxpayers is still subject to the possible normal audit selection. The taxpayer needs to be prepared to defend filing a SFCP and be able…
IRS Announces Increased Enforcement on Form 5471
…“audit ready” file on those issues in case of an audit. Please also note that the Internal Revenue Code section 6501(c)(8) provides that the failure to file Form 5471 results…
New Jersey Transfer Inheritance Tax : How the Tax Works
…form must be filed with the Individual Tax Audit Branch – Inheritance and Estate Tax office in Trenton. If a husband and wife own real estate as tenants by the…
How To Limit An Executor’s Personal Liability For A Decedent’s Unpaid Taxes
…invites audit and should be filed only when an audit is forthcoming or expected. To comply with Treasury Regulation § 301.6501(d)-1, the executor can complete Form 4810. Apply for Discharge…
FATCAts
…follows a similar 2009 programme, and the recently formed IRS Global High Wealth (GHW) audit unit focused on GHW compliance. Together, these enforcement mechanisms may have a significant impact on…
National Taxpayer Advocate Delivers Annual Report to Congress that Criticizes Offshore Voluntary Disclosure Programs
…“opt out” and be audited to obtain a lesser penalty. Uncertainty about what penalty might apply in the audit, the IRS’s one-sided interpretation of the program terms, processing delays, and…
Streamlined Filing Compliance Procedure’s New Revisions to Streamlined Domestic Offshore Procedures (SDOP)
…does not automatically select the taxpayer for an IRS audit, the taxpayers is still subject to the possible normal audit selection. The taxpayer needs to be prepared to defend filing…
Keeping Tax Papers
…your tax return to complete an audit of you. That is why you want to keep records substantiating your tax return data a minimum of three years. For example, if…
Streamlined Filing Compliance Procedure’s New Revisions to Streamlined Foreign Offshore Procedures (SFOP)
…SFCP does not automatically select the taxpayer for an IRS audit, the taxpayers is still subject to the possible normal audit selection. The taxpayer needs to be prepared to defend…
IRS Official Provides Insights for the new IRS Streamlined Compliance Procedures
…audit and criminal liability protection offered by the OVDP, according to Jennifer Best, senior adviser to the IRS deputy commissioner (International). The IRS June 18 announced it was expanding its…
The IRS Large Business and International division (LB&I) has announced a new Offshore Private Banking enforcement campaign
…accounts at offshore private banks. This campaign addresses tax noncompliance and the information reporting associated with these offshore accounts. The IRS will initially address tax noncompliance through audit examination and…
Benefits and consequences of entering or failing to enter the Offshore Voluntary Disclosure Initiative program
…Involuntary Discovery as a result of FATCA and Mutual Information Sharing Treaties Criminal Prosecution Lengthy comprehensive audit examination of tax returns 1-5 years’ jail sentence (based on magnitude of un-reporting)…
IRS collects over $5 billion in its its offshore voluntary disclosure programs
…specific financial institution. Our law firm expects unabated aggressive enforcement of the US tax laws, including FATCA with increased criminal prosecutions and civil audit examinations. We have been advising our…
OVDI: Requesting issuance of a FBAR warning letter instead of penalties
…meantime, our law firm expects unabated aggressive enforcement of the US tax laws, including increased criminal prosecutions and civil audit examinations. We have been advising our clients to expect the…
Details of the Streamlined Foreign Offshore Procedures (SFOP)
…for an IRS audit, the taxpayers is still subject to the possible normal audit selection. The taxpayer needs to be prepared to defend filing a SFCP and be able to…
Details of the Streamlined Domestic Offshore Procedures
…of laws, knowledge and violations. Although filing an SFCP does not automatically select the taxpayer for an IRS audit, the taxpayers is still subject to the possible audit selection. The…
Checklist of tax forms for taxpayers with foreign assets
…US tax laws, including increased criminal prosecutions and civil audit examinations. We have been advising our clients to expect the unexpected (and the worst) in their tax treatment and disclosure…
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…