Search Results for: irs appeal
IRS collects over $5 billion in its its offshore voluntary disclosure programs
…those hiding assets offshore,” said IRS Commissioner Doug Shulman. “People are finding it tougher and tougher to keep their assets hidden in offshore accounts.” Shulman added the IRS OVDPs have…
The New IRS Voluntary Disclosure Practice: Not a Good Deal for Noncompliant Taxpayers
…Office of Appeals. The VDP does not impact the existence of the IRS’ Streamlined filing compliance procedures. The Advantages and Disadvantages of the IRS New Voluntary Disclosure Practice: Advantages: Avoidance…
IRS offers tax opportunity to Americans living abroad
…secret offshore accounts that they have knowingly failed to disclose to the IRS. An IRS statement said the new guidelines were for “low compliance risk” taxpayers, generally people who have…
New IRS FBAR Practice Unit
The IRS LB&I recently issued its Practice Unit on FBARs. Practice Units are “job aids” and training materials intended to describe for IRS agents helpful practices about tax concepts in…
India Expected to Sign FATCA Agreement Tomorrow
…shortly publish regulations for implementation of FATCA. Who is Reported? Many Indian financial institutions have already registered on the IRS’s FATCA Registration Portal. The IRS has published a searchable list…
How to Avoid Criminal Prosecution Through Voluntary Disclosure
The Voluntary Disclosure Practice is an IRS-created option of the IRS Criminal Investigations for U.S. Taxpayers at risk for criminal prosecution due to a tax-related offense. Taxpayers who have willfully…
Expect new aggressive IRS targeted enforcement next year.
…budget and staff, which will enable them to data-mine and intelligently scrutinize tax returns. As a result, the IRS is smarter than ever. In addition, current IRS Commissioner Chuck Rettig,…
Streamlined Filing Compliance Procedure’s New Revisions to Streamlined Foreign Offshore Procedures (SFOP)
…February 2016, the IRS revised Form 14653 to require more disclosure. Now the IRS also instructs the taxpayer to: Include the whole story including favorable and unfavorable facts. Specific reasons,…
Demystifying IRS Agents
…Like many organizations, the IRS has limited resources, and it should use them wisely. IRS Agents, with Taxpayer consent, have the ability to complete an exam more quickly. Also, IRS…
Beware: India to sign FATCA agreement with US for sharing of information
…U.S. Internal Revenue Service (IRS). The agreement would provide the Internal Revenue Service (IRS), access to details of all offshore accounts and assets beyond a threshold limit held by Americans…
Finally: IRS Reminds Those with Foreign Assets of U.S. Tax Obligations
…to address the IRS’ alleged shortcomings in educating taxpayers with foreign accounts. As a result, the IRS issued IR-2013-54 on May 23, 2013 which is provided below. WASHINGTON — The…
New Post-OVDP IRS Voluntary Disclosure Procedures Announced
…disclosures (both domestic and offshore) received by the IRS after the closing of the OVDP. The new procedure updates the old Voluntary Disclosure Practice of the IRS to provide taxpayers…
New IRS Relief for Taxpayers Experiencing COVID-related Difficulties
The IRS has announced new initiatives to help taxpayers experiencing Covid-related difficulties (which probably applies to most people) who have unpaid federal tax liabilities. Specifically, the IRS has announced the…
IRS Revises Delinquent International Information Return Submission Procedure (DIIRSP)
…not under a civil examination or a criminal investigation by the IRS and have not already been contacted by the IRS about the delinquent information returns should file the delinquent…
Delinquent or unfiled IRS Form 5471
IRS Form 5471 is a form required to be filed by US owners of foreign corporations. The form and filing requirements are complicated, and the penalties and consequences for non-filing…
HSBC and NRI Bank Accounts: Could It Spread to Other Banks?
…rule, the IRS doesn’t comment on ongoing investigations”. On April 7, US authorities sought an order from a federal court in San Francisco, authorising the US IRS to request for…
Analysis of the new 2012 Offshore Voluntary Disclosure Program (OVDP)
…going forward, the IRS cautioned. For example, the IRS may increase penalties in the program for all or some taxpayers or defined classes of taxpayers—or decide to end the program…
IRS’ New “Dirty Dozen” list of tax scams
…of several typical IRS enforcement and compliance priorities, but the IRS indicated that a wholly separate enforcement and compliance priorities list is forthcoming. Some selected new scams include: Senior Fraud:…
Government Report Advises IRS to Increase Awareness of Offshore Account Rules to Help Immigrants
…not targeted outreach efforts to new immigrants, the GAO’s report said. “Obtaining information on how taxpayers found out about IRS’s offshore voluntary disclosure programs could help IRS better identify populations…
How Will the IRS Find Out By Your Foreign Account? Let’s Count the Dozens of Ways
…under investigation by IRS and Department of Justice G. 110 clients turned over to IRS by Swisspartners If you have risk of discovery of tax non-compliance, you must seek the…
Taxpayer’s Beware: Proving Non-Willful Conduct in the new IRS Streamlined Filing Compliance Procedures
…reasons, provide the individual reasons for each spouse separately in the statement of facts.” See the “non-willful” certification statement available at http://www.irs.gov/pub/irs-utl/CertUSResidents.pdf. Advocacy is required to affirmatively and persuasively demonstrate…
IRS Uses New Funding to Target US Persons with Malta Accounts
…Act’s passage. The IRS has been investigating the Malta alleged loophole and has pledged a crackdown on such tax evasion schemes. The Treasury said, “As part of the IRS’ efforts…
Penalty relief for International Information Forms 5471, 5472, and 8865
…in penalty amount for Form 5472 and updated IRS Internal Revenue Manual (IRM) language on penalty abatement, tax advisors must know the procedures for the assessment and abatement of these penalties….
Internal Revenue Service announces new International Data Exchange Service: The Beginning of Information Sharing
…and have a global intermediary identification number (GIIN) that appears on the IRS FATCA FFI list. The IRS has published a searchable list of financial institutions. The FFI List Search…
More Tax Complexity: New Form 8938
…IRS’ initial warning. Additionally, the IRS may apply a 40% penalty on the taxes from non-disclosed assets. Unlike many US taxpayer tax matters, the filing requirements leave little guess work….
Analysis: IRS New Disclosure Program
On November 29, 2018, the IRS released a memorandum that addressed the process for all voluntary disclosures following the end of the Offshore Voluntary Disclosure Program (“OVDP”) on September 28,…
The IRS can revoke your passport
…has expressed dissatisfaction with various elements of how IRS administers IRC § 7345. For example, in her summer 2017 report, her office expressed concern that IRS does not notify taxpayers…
IRS Reminds U.S. citizens and dual citizens about U.S. filing requirements
In a fact sheet (IRS FS-2011-13) released last week, the IRS reminded U.S. citizens and dual citizens of the United States and foreign countries who live abroad about U.S. filing…
IRS Warning Letter Warns Foreign Business Owners About Section 965 Transition Tax Enforcement
The IRS has recently begun sending “soft letters” (warning letters) to U.S. taxpayers owning foreign companies about IRC Section 965 transition tax compliance. In July 2020, The IRS Large Business…
New FATCA Enforcement Expected
…IRS has permitted numerous nations to benefit from having status as IGA, even if they did not have a finalized IGA in force. In IRS Announcement 2016-17, however, the IRS…