Search Results for: irs appeal
IRS Collects $10 Billion From Voluntary Disclosures of Foreign Assets
…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…
The IRS Needs Help
The IRS is a malfunctioning mess. A recent report from the National Taxpayer Advocate, states that the IRS has failed to answer taxpayers’ requests for assistance. I have been a…
What to Expect if the IRS Audits Your Employee Retention Credit
…IRS ERC audit: Notice: You will receive a notice from the IRS informing you that your return has been selected for audit. This notice will outline the next steps you need…
IRS Has Ended Unannounced Visits to Collect
…with a revenue officer. The IRS has ended most unannounced visits to taxpayers by revenue officers. Ending unannounced visits to taxpayers will increase confidence in IRS’s tax administration work and…
U.S. Taxpayers at New Risk of Audit from OVDP Declines and Withdrawals Campaign
…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…
IRS Releases New IRS Form W8-BEN: U.S. persons beware of completing such form at the request of a third party
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…
Tax Court Rules IRS Cannot Assess or Collect Form 5471 Penalties
…recording a tax liability on the IRS’s records for a taxpayer. After assessment and failure to pay, the IRS can enforce the collection of tax, penalties and interest by asserting a lien…
IRS Launches Second Offshore Voluntary Disclosure Initiative After Successful Prosecution
…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…
Malta Pension Plan Being Investigated by IRS Criminal Investigation Division
…development last week, IRS Criminal Investigation (IRS-CI) Special Agents began visiting taxpayers and advisors who have participated in, or advised on, Malta Pension Plans. IRS-CI agents are issuing summons to…
Is First-Time Abatement Applicable In International Penalty Cases?
…Appeals Employees The memorandum will effectively change procedures for IRS employees with international appeals and penalty cases. Per the instructions, the updated guidance regarding IRM 8.11.5, Penalties Worked in Appeals,…
Comments on IRS Form 3520 to Report Foreign Gifts
…find the IRS ultimately abates (canceling) almost all such penalties. The last comment asks the IRS to abate Form 3520 late penalties via the expansion of its popular First Time…
IRS reminds those with foreign assets about U.S. tax obligations
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 Voluntary Disclosure Program lets employers who received questionable Employee Retention Credits pay them back
…provided.” This suggests that the IRS will electronically data mine disclosure applications to find and investigate predatory ERC promoters. The IRS has used this strategy many times before to identify…
New IRS guidance Announced for IRS Streamlined Offshore Procedures.
…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…
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,…
New IRS Disclosure Program Announced for Non-Resident Taxpayers: Streamlined Foreign Offshore Procedures
…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….
National Taxpayer Advocate calls IRS Penalties Draconian and Inefficient
…ignores the statement until after it assesses the penalty. Although the IRS furnishes taxpayers with the right to go to the IRS Independent Office of Appeals, which often concedes these…
Traveling? Resolve Tax Debt Before Getting Your Passport
…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 Form 8938 and the Offshore Voluntary Disclosure Program (OVDP)
…a significant tool for the IRS to identify the scope of international tax non-compliance of a given U.S. taxpayer. The reason why Form 8938 is so useful for the IRS…
IRS’ first-time penalty abatement administrative waiver (FTA)
…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…
New IRS practice unit: “Substantial compliance” doctrine, international information return penalties
…particularly Form 5471. The IRS recently released a new International Practice Unit (“IPU”) on failures to file form 5471. IPUs are meant to act as a guide for IRS examiners…
What I learned at the 2022 National Institute on Criminal Tax Fraud and Tax Controversy in Las Vegas
…IRS. – The IRS has started training new personnel with more frequency and size. For example, the IRS just finished training 35 new criminal investigation special agents earlier this month….
Offshore Compliance Programs Generate $8 Billion; IRS Urges People to Take Advantage of Voluntary Disclosure Programs
…dollars. The IRS has also pursued criminal charges leading to billions of dollars in criminal fines and restitutions. The IRS remains committed to stopping offshore tax evasion wherever it occurs….
How to Defend Against FBAR Penalties
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…
IRS Announces New Clarifying FAQs for Streamlined Offshore Compliance Program
…partial interest. The IRS will apply the principles announced in OVDP FAQs 31 through 33, 35.1, and 38 through 41. This interestingly may be the first time where the IRS…
Finally. Government Accountability Office makes recommendations to the IRS for tax laws education to immigrants
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…
New IRS Voluntary Disclosure in 7 Steps
The following are the seven steps of the new updated IRS voluntary disclosure process: A taxpayer will make a voluntary disclosure preclearance request using IRS Form 14457 to IRS Criminal…
The IRS is Hiring: Expect New Enforcement
…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…
What HSBC India Accountholders Can Expect From the IRS
…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…
A solution in a tough tax season: the IRS Streamlined Offshore Procedures
…may be made on one of the following forms initially released by the IRS in August 2014: For U.S. taxpayers residing in the U.S. – IRS Form 14654: Certification by…