The IRS Large Business and International division (LB&I) has announced a new Post OVDP Compliance enforcement campaign

- By : Parag Patel

The new Post OVDP Compliance enforcement campaign was recently identified through LB&I data analysis and suggestions from IRS employees. IRS employees likely saw that many taxpayers were not properly reporting…

Automatic Form 5471 and 5472 Penalties in Spotlight by 2020 National Taxpayer Advocate Report

- By : Parag Patel

…unavailability of the requisite information, and IRS error. The report recommends manual penalty assessment and automatic abatement of penalties. We applaud the IRS for noticing these unfair penalties. Unfortunately, the…

IRS Announces New Statistics Regarding Voluntary Disclosures

- By : Parag Patel

…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…

IRS Notice CP 503: IRS Second Notice of Balance Due: What to Do

- By : Parag Patel

An IRS CP 503 notice is a letter that the IRS sends out to individuals as a reminder and a means to collect on a tax debt balance. This letter…

Run to the Door: IRS Terminates Offshore Voluntary Disclosure Program (OVDP) effective September 28, 2018

- By : Parag Patel

IRS Issue Number: IR-2018-52 IRS to end offshore voluntary disclosure program; Taxpayers with undisclosed foreign assets urged to come forward now WASHINGTON – The Internal Revenue Service today announced it…

For the First Time IRS Issues Information on 2011 Offshore Voluntary Disclosure Initiative (OVDI) in Hindi Language

- By : Parag Patel

In an effort to reach all taxpayers, including those ensnared in the pending HSBC subpoena to disclose customer names of non-resident indian customers with offshore accounts, the IRS has published…

New IRS Subpoenae and IRS Data Mining Expected

- By : Parag Patel

…The IRS uses John Doe summonses to obtain information when it searches for tax fraud by individuals whose identities are unknown. This is a expansive order, allowing the IRS to…

IRS Notices for OVDI Program

- By : Parag Patel

When the IRS receives payment with amended tax returns for taxes, interest and penalties, the IRS may misapply the payment. This results in IRS notices. Reminiscent of the mistakes of…

Reasons to Opt Out of the 2011 OVDI Program

- By : Parag Patel

…opt out is unacceptable, then you can appeal to the Appeals Branch of the IRS. If your penalty post Appeal is unacceptable, then you can appeal to the Tax Court….

National Taxpayer Advocate Delivers Annual Report to Congress that Criticizes Offshore Voluntary Disclosure Programs

- By : Parag Patel

…cause.” The IRS’s one-sided interpretations of its OVD FAQs, which were not explained, appealable, or published, eroded confidence that the IRS would be reasonable in a post-opt-out examination. The IRS

30-DAY LETTERS VS. 90-DAY LETTERS IN TAX AUDITS

- By : Parag Patel

…agree to the IRS’ findings. The taxpayer can either agree, go over the examiner’s head and take the issue up with the IRS Appeals Office, or do nothing (in which…

IRS issues new information document request (IDR) directives

- By : Parag Patel

…of goals before they meet IRS agents in their opening conference and engage in interim reviews with the IRS during the quality examination process. Typically an IRS agent has an…

IRS Official Provides Insights for the new IRS Streamlined Compliance Procedures

- By : Parag Patel

…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…

IRS Announces New 2012 Offshore Voluntary Disclosure Program (OVDP)

- By : Parag Patel

IRS said the new program’s terms and penalties could change at any time, and the IRS may opt to end the program at any time. “As we’ve said all along,…

Correcting Common FBAR Errors

- By : Parag Patel

…being filed pursuant to the “IRS’s Delinquent FBAR Submission Procedures.” 3. File Pursuant to the IRS’s Streamlined Filing Compliance Procedures The IRS’s Streamlined Filing Compliance Procedures (commonly referred to as…

IRS Announces Key Milestone in FATCA Implementation; U.S. Begins Reciprocal Automatic Exchange of Tax Information under Intergovernmental Agreements

- By : Parag Patel

…is a major milestone in IRS efforts to combat offshore tax evasion through FATCA and the intergovernmental agreements,” said IRS Commissioner John Koskinen. “FATCA is an important tool against offshore…

IRS Collects $10 Billion From Voluntary Disclosures of Foreign Assets

- By : Parag Patel

…taxpayers to come forward, the IRS said last Friday in a public statement. The latest figures indicate 55,800 taxpayers have entered the IRS’s Offshore Voluntary Disclosure Program to resolve their…

IRS Releases New IRS Form W8-BEN: U.S. persons beware of completing such form at the request of a third party

- By : Parag Patel

The long awaited revised IRS Form W8-BEN has been recently released in July 2017. The major changes to IRS Forms W8, particularly W-8BEN-E (which is still in draft form), have…

U.S. Taxpayers at New Risk of Audit from OVDP Declines and Withdrawals Campaign

- By : Parag Patel

…2009, but were either (i) denied entry by IRS Criminal Investigation division, or (ii) withdrew prior to formal acceptance (defined by acceptance by the IRS of the applicant’s voluntary disclosure…

Beware: IRS Reminds Taxpayers of FBAR Deadline

- By : Parag Patel

…Compliance Act, or FATCA, phases in and other international compliance efforts have raised awareness among taxpayers with offshore assets, the IRS noted. The IRS is encouraging taxpayers with foreign assets,…

New IRS guidance Announced for IRS Streamlined Offshore Procedures.

- By : Parag Patel

…file under the Streamlined Domestic Offshore Procedures (SDOP) or the Streamlined Foreign Offshore Procedures (SFOP). Our firm has recently received many inquiries regarding these new IRS Streamlined Offshore Procedures. These…

IRS reminds those with foreign assets about U.S. tax obligations

- By : Parag Patel

The IRS again reminded taxpayers yesterday about their reporting obligations for foreign assets and income. The reminder again represents the IRS’ targeted enforcement of tax laws for reporting obligations for…

New IRS Disclosure Program Announced for Non-Resident Taxpayers: Streamlined Foreign Offshore Procedures

- By : Parag Patel

…not meet the substantial presence test of IRC section 7701(b)(3). For more information on the substantial presence test, see IRS Publication 519, which may be found at IRS Publication 519….

IRS Launches Second Offshore Voluntary Disclosure Initiative After Successful Prosecution

- By : Parag Patel

IRS. Dhake will face as imprisonment for five years. The IRS may issue a summons to HSBC Bank to disclose its customers with foreign bank accounts. The IRS’ 2011 Offshore…

Traveling? Resolve Tax Debt Before Getting Your Passport

- By : Parag Patel

…to take to resolve the debt. Please note, the IRS doesn’t send copies of the notice to powers of attorney. IRS telephone assistors can help taxpayers resolve the debt, for…

IRS’ first-time penalty abatement administrative waiver (FTA)

- By : Parag Patel

…the IRS has assessed against them for the first time. In effect, the IRS rewards typically compliant taxpayers with one-time penalty amnesty, which can save the taxpayer penalty dollars. Earlier…

The IRS is Hiring: Expect New Enforcement

- By : Parag Patel

…speech given by the new IRS Commissioner Chuck Rettig where he mentioned a few intriguing areas of concern. Despite budget cuts, Commissioner Rettig stated that the IRS is rapidly increasing…

How to Defend Against FBAR Penalties

- By : Parag Patel

Following the IRS’ successful 2009 and 2011 offshore voluntary compliance initiatives, tax professionals should expect an increase in IRS examination activity of taxpayers who did not enter into these compliance…

Finally. Government Accountability Office makes recommendations to the IRS for tax laws education to immigrants

- By : Parag Patel

In latest report from a government watchdog agency called the Government Accountability Office (GAO) the GAO makes recommendations to the IRS, and the IRS pays attention. Those recommendations could put…

What HSBC India Accountholders Can Expect From the IRS

- By : Parag Patel

IRS discovers the foreign financial account, the taxpayer’s accountant or other non-attorney could become a witness for the IRS against the taxpayer. This would not be the case if an…