Search Results for: fatca letter
New Law’s Reporting Requirements Make It Very Likely That the IRS Will Now Know About Your Foreign Account
Under the recently enacted Foreign Account Tax Compliance Act (“FATCA”), foreign financial institutions (“Financial institutions” is broadly defined to include banks, mutual funds, funds of funds, exchange-traded funds, hedge funds,…
IRS issues new information document request (IDR) directives
…than they would have under the old regime. The IRS will issue a delinquency notice within 10 days of a missed deadline, issue a presummons letter if the taxpayer does…
New Jersey Department of Revenue publishes “Manual of Audit Procedures”
…than $1,000, the audit should be discontinued. Of particular note is the “Walk Away” section in the manual. Our office recently received a walkaway letter from a taxpayer after we…
Opting-out of the Offshore Voluntary Disclosure Initiative: FBAR Penalty Mitigation Guidelines
…and circumstances of a particular case do not justify a penalty. If there was an FBAR violation but no penalty is appropriate, the examiner should issue the FBAR warning letter,…
IRS Has Ended Unannounced Visits to Collect
…taxes and unfiled tax returns. Going forward, the IRS will advise taxpayers through a mailed letter that they are delinquent and advise them on how to set up an appointment…
Planning for Dependent (or not Independent) Family Members
…SNT can be moved into an ABLE account, and the beneficiary can use it for any qualified disability expense. Prepare (and update) a letter of intent or guidance. This is…
ERC Disallowance Letters 105C Sent to Taxpayers
…disallowing incorrect credits before they enter the audit process. The IRS plans to send additional letters beyond the disallowance letters. It’s also finalizing plans for a special voluntary disclosure program…
The IRS is Assessing Form 3520 Foreign Information Reporting Penalties
…CP 215 notice, the IRS will send the taxpayer Letter 1058, Notice of Intent to Levy and Notice of Your Right to a Hearing, or LT11 Final Notice of Intent…
Delinquent FinCen Form 114 (FBAR) Filings
…Letter for FBAR Violations: The IRS uses a warning letter in lieu of asserting penalties for failure to file an FBAR to bring the individual into compliance. Read this article….
IRS Extends Late Portability Election Automatic Relief from 2 to 5 Years
…began offering the two-year relief period, “the IRS has continued to issue numerous letter rulings” from estates that missed that deadline, placing “a significant burden” on IRS resources. A “significant…
New IRS Voluntary Disclosure in 7 Steps
…OVDP program). CI will not process tax returns or tax payments. CI will notify the taxpayer by letter of preliminary acceptance of the voluntary disclosure submission. CI will forward the…
Penalties for Not Filing Form 3520
…all relevant facts and documents supporting the taxpayer’s position. If no action is taken, the taxpayer will receive one of three letters: Letter 1058, Notice of Intent of Your Right…
5 Estate Planning Tips to Avoid Disputes
…to the attorney’s office without other family members or intended beneficiaries. Another recommendation might be to prepare a letter discussing the client’s desires and what he or she wishes to…
2011 Offshore Voluntary Disclosure Initiative Frequently Asked Questions (FAQs) and Answers
…step for a taxpayer making an offshore voluntary disclosure is the submission of the Offshore Voluntary Disclosures Letter. This letter will be reviewed by IRS Criminal Investigation (CI), and taxpayers…
In Addition to HSBC, Credit Suisse Also Being Investigated for Offshore Activities
On July 14, 2011, Credit Suisse received a letter notifying it that it is a target of a Justice Department investigation. A target letter is significant. It likely means that…
New IRS IRM with Updated Streamlined Filing Compliance procedures
…not restrict the failure to file or failure to pay penalties and do not input TC 971 with Action Code (AC) 178. NOTE: The 178C letter includes language advising the…
OVDP New Forms Announced by IRS
The IRS has simplified the process of entering the OVDP Program by issuing the following forms: Form 14457 – Offshore Voluntary Disclosure Letter Form 14454 – Offshore Voluntary Disclosure Program…
The IRS Large Business and International division (LB&I) has announced a new Offshore Private Banking enforcement campaign
…soft letter treatment 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…
IRS announces new Streamlined Filing Compliance Procedures
…convert their disclosure to one of the two more lenient streamlined programs – as long as the taxpayer has not yet signed the final Form 906 closing letter that is…
What if You Missed the OVDI Deadline?
…of discovery by the IRS, and the attendant increased penalties and criminal exposure, is the Foreign Account Tax Compliance Act (FATCA) recently passed by Congress. Under FATCA, which goes into…
Avoiding and Defining Willfulness
…not disclose such offshore accounts and assets. In addition, many U.S. taxpayers, both domestic and international, are facing pressure from foreign banks to disclose their U.S. taxpayer status (via FATCA…
The IRS is Hiring: Expect New Enforcement
…Account Tax Compliance Act (“FATCA”). A basic comparison of FATCA data and taxpayers’ filing data could yield many thousands of instances of noncompliance. In other words, the IRS will be…
New Leak of Offshore Accountholders Highlights the Need to Clean Up
…with other countries under the Foreign Account Tax Compliance Act (FATCA) have cracked open access to bank information previously held in secret in other countries. If a foreign bank refuses…
IRS Collects $10 Billion From Voluntary Disclosures of Foreign Assets
…Compliance Act, or FATCA, as part of the HIRE Act. The legislation requires foreign financial institutions to report on the holdings of U.S. customers or else face stiff penalties of…
Upcoming live video webinar: U.S.-India Tax Planning: Reporting Issues, Traps to Avoid, Tax Treaties, FTC, FACTA/FBAR Reporting, Passive Income
…credit FATCA and FBAR reporting Inheritance taxes Benefits The panel will review these and other key issues: Filing obligations in the U.S. and India for certain taxpayers Taxable income, reportable…
US Entities with foreign assets have more information reporting
…effective immediately, are linked to the Foreign Account Tax Compliance Act (FATCA). When FATCA was enacted in 2010, the new Section 6083D was added to the Internal Revenue Code requiring…
US passport and green-card has lost its glamour
A US passport or green-card is losing its glamour and appeal. Some people are surrendering their prized green cards because of the US Foreign Account Tax Compliance Act (FATCA), which…
IRS Announces New Investigative Units
…leads from information received through the Swiss Banking Program, the Foreign Account Tax Compliance Act (FATCA) and the Panama Papers investigation, among other sources. The effort is also clearly intended…
Offshore Compliance Programs Generate $8 Billion; IRS Urges People to Take Advantage of Voluntary Disclosure Programs
…including the offshore program and streamlined procedures, to come back into full compliance with their tax obligations.” Under the Foreign Account Tax Compliance Act (FATCA) and the network of intergovernmental…
Caution: Foreign Businesses Require Additional Reporting
…may find that their U.S. connection brings unwanted U.S. reporting requirements and scrutiny. Aside from the CFC rules discussed above, the new FATCA (Foreign Account Tax Compliance Act) requires ownership…