Search Results for: fatca letter
Helpful Non-willful FBAR penalty case decided by court
…his counsel provided detailed arguments in a letter as to why Mr. Moore acted with reasonable cause In December of 2012, IRS responded in a brief letter upholding the penalties…
IRS Notice CP 503: IRS Second Notice of Balance Due: What to Do
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…
Resolving IRS disputes through audit reconsideration
…the SFR process. For example, suppose two married taxpayers’ jointly filed return was audited by the IRS. Subsequently, the IRS mailed a notice of deficiency (90-day letter) that stated that…
Answers to Common Questions for IRS CP3219N Notice of Deficiency (90-day letter)
What you need to do If you want to challenge the deficiency determination, file a petition with the Tax Court. File your tax return immediately (no later than 90 days…
U.S. Taxpayers at New Risk of Audit from OVDP Declines and Withdrawals Campaign
…letter (sometimes referred to as “pre-acceptance letter”) into the OVDP. Targeted Taxpayers The IRS has stated they anticipate that about 6,000 taxpayers may be affected by this campaign. The LB&I…
IRS Announces Major New changes to the Offshore Voluntary Disclosure Program
…United States. The agency says the changes are anticipated to provide thousands of people a new avenue to come into compliance with their U.S. tax obligations. They come as FATCA…
Beware: IRS Reminds Taxpayers of FBAR Deadline
…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,…
Common Issues for US-India Tax Reporting
…financial institutions such as mutual funds or fixed deposits, need to file a FATCA self-certification form. The FATCA certification form WILL LEAD to disclosure to the US government. So know…
Letters of Instruction, or Ethical Wills
…thoughts to your loved ones. To supplement your will, consider writing a letter of instruction. A letter of instruction, also known as an ethical will, is an informal (not a…
NJ Division of Taxation Offers Offshore Voluntary Compliance Initiative
…apply to the Division by submitting a letter requesting acceptance into the program. The letter should contain the following items: Applicant’s complete name and address NJ tax identification number and…
New York State Bar Association Proposes OVDI Changes to IRS
…Counsel and Acting Assistant U.S. Treasury Secretary on how to make the OVDI 2011 fairer and more administrable. Readers can review or download the letter here. The letter format is…
More Tax Complexity: New Form 8938
…been labeled the “Foreign Account Tax Compliance Act”. FATCA is part of the Hiring Incentives to Restore Employment (HIRE) Act, which was designed to enforce higher tax compliance among U.S….
How Will the IRS Find Out By Your Foreign Account? Let’s Count the Dozens of Ways
1. FATCA (Foreign Account Tax Compliance Act of 2009) requires disclosure of your account information. A. July 1, 2014 FATCA withholding began. B. FATCA requires a 30 percent withholding tax…
Beware of U.S. tax consequences to a foreign trust with a U.S. beneficiary
…FATCA Entity Reporting: FATCA imposes a 30% withholding tax on payments to “foreign financial institutions” (“FFIs”) that do not comply with certain disclosure requirements about their U.S. account holders. A…
US Department of Justice Encourages Swiss banks to Disclose Information
…with U.S. taxpayers, but nonetheless want a resolution of their status, may apply for a non-target letter. Those banks may not submit a letter of intent until July 1, 2014….
Foreign Gift Received: Form 3520 Penalties Eliminated in New Court Case
…are assessed. Wrzesinski appealed and even provided a letter from his accountant acknowledging the incorrect advice, but IRS appeals only abated 80% of the penalties based on the ‘Hazards of…
File a Protective Claim for Refund for Possible OVDP Opt Out Cases
…even authorized to issue a Letter 3800 (a warning letter) that abates the foreign reporting penalties for one or many of the tax years entirely. To clarify the process, the…
IRS starting to audit employee retention credit (ERC)
…information to the agency. Several law firms and media outlets are reporting that some taxpayers who claimed the ERC began receiving IRS Letter 6612 (Audit Initiation Letter) in January. The…
2016 US Dept of Justice (DOJ) Tax Division: FBAR penalty collection cases
…generally are beyond the reach of the government. Upon assessment, the IRS makes notice and demand for payment by sending Letter 3708 to the taxpayer and power of attorney on…
Top 10 factors to consider before deciding to opt out of OVDI or OVDP
…arguments for the full abatement of all penalties. 4. When the taxpayer’s OVDI or OVDP submission has been examined he will receive a Form 906 closing letter from the IRS…
New guidance on fixing a botched IRA stretch after it’s “too late”
…withdrawals don’t start on time, can you still rectify the situation to preserve the tax deferral? A recent private letter ruling procured our by our law firm indicates the answer…
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…
Special Needs Planning Mistakes
…of the law can allow parents to establish a SNT that provides for the particular needs of their child. 3. Failing to prepare a letter of intent. In addition to…
New Jersey Tax Amnesty program
…and prior to September 1, 2017. The Division of Taxation recently mailed a letter to all taxpayers who are known to have amnesty-eligible deficient and/or delinquent accounts. According to the…
The IRS Large Business and International division (LB&I) has announced a new Post OVDP Compliance enforcement campaign
…streams. Soft letters are IRS correspondence to targeted taxpayers identifying tax noncompliance and passively seeking compliance. Failure to respond to such letters may result in audit or penalties and possible…
Foreign Account Tax Compliance Act – Traps for the Unwary
For anyone who has clients or family members that live and work abroad, the new Foreign Account Tax Compliance Act (FATCA) is a real problem. Although this Act is supposed…
50% Penalty for Taxpayers Who Hold Accounts at a Bank Under Investigation
…the list may grow as FATCA is implemented, the current list of those banks include: HSBC India • UBS AG • Credit Suisse AG, Credit Suisse Fides, and Clariden Leu…
IRS announces two new intriguing targeted enforcement campaigns
…for not reporting foreign accounts. In 2011, in response to the Foreign Account Tax Compliance Act (FATCA), the IRS announced a new amnesty program called the 2011 Offshore Voluntary Disclosure…
Becoming Un-American: Record number of US citizens renounce their US citizenship
…FATCA requires individuals to report certain foreign assets and banks to disclose all foreign accounts held by Americans. Key FATCA disclosure rules take effect this year that will make avoiding…
New voluntary disclosure program for offshore accounts in 2011
…Act (“FATCA”) ensures that more information about foreign accounts will become available to U.S. enforcement authorities. FATCA will make it much more likely that any foreign financial institution, and non-financial…