Search Results for: streamlined filing compliance procedures
IRS Enforcement Campaign Targets High-Income Non-Filers
…examining large corporations and high-net-worth individuals. Key Actions The IRS has identified over 125,000 instances of high-income non-compliance. Targeted taxpayers will receive CP59 Notices detailing steps for achieving compliance. Those…
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…
New FATCA Enforcement Expected
The IRS has tightened its enforcement of the Foreign Account Tax Compliance Act (“FATCA”). FATCA was enacted in 2010 by Congress to target non-compliance by U.S. taxpayers using foreign accounts….
IRS list of “dirty dozen” tax scams
Hiding income in offshore accounts, identity theft, return preparer fraud, and filing false or misleading tax forms top the annual list of “dirty dozen” tax scams in 2011, the Internal…
Internal Revenue Service again issues annual reminder to US persons to report foreign accounts and foreign income
…$50,000 if the IRS contacts you and you fail to respond. The IRS reminder notice is provided below. Foreign Account Filings Top 1 Million; Taxpayers Need to Know Their Filing…
The IRS’s 2022 Dirty Dozen tax scams
…even when they have a legal filing requirement, and especially those earning more than $100,000 per year who don’t file, represent a compliance problem that continues to be a top…
Foreign Retirement Plans: New IRS Exemption from Required Information Reporting on Forms 3520 and 3520-A
…as an individual who is, or at any time was, a U.S. citizen or resident and who is compliant (or comes into compliance) with all requirements for filing a U.S….
Some FBAR Deadlines Extended
…over but no financial interest in one or more foreign financial accounts, specifically individuals whose FBAR filing requirements may be affected by the signature authority filing exemption in 31 CFR…
IRS Reminds (again) Taxpayers to Report Foreign Income and Assets
…e-filing is available through the BSA E-Filing System at http://bsaefiling.fincen.treas.gov/main.html. c) A new form was introduced, FinCEN Form 114a, Record of Authorization to Electronically File FBAR, to authorize a third…
Corporate Transparency Act (CTA) Reporting Company Analysis and FAQs
…is created in a U.S. jurisdiction requiring such filing, it is a reporting company unless an exemption applies. Similarly, not all states require foreign entities to register by filing a…
Hiding Money or Income Offshore Among the “Dirty Dozen” List of Tax Scams for the 2015 Filing Season
…scams known as the “Dirty Dozen” for the 2015 filing season. “The recent string of successful enforcement actions against offshore tax cheats and the financial organizations that help them shows…
Automatic Form 5471 and 5472 Penalties in Spotlight by 2020 National Taxpayer Advocate Report
…abatement rates (up to 71% of penalty amounts), much of this late filing is ultimately determined by the IRS to result from benign circumstances, including ignorance of the filing requirements,…
Navigating Foreign Waters: The Complex Requirements of Foreign Accounts Compliance
…21, 2011 – 7:00 p.m. to 10:00 p.m. Navigating Foreign Waters: The Complex Requirements of Foreign Accounts Compliance Parag P. Patel, Esq. With the IRS aggressively targeting taxpayers with unreported…
IRS Form 8938 and the Offshore Voluntary Disclosure Program (OVDP)
…the 2011 OVDI just ended on September 9, 2011. However, if one analyzes the number of new developments in international tax compliance over the past several years, then the surprise…
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 Increased Enforcement on Form 5471
On April 16, 2019, the Large Business and International (LB&I) Division of the Internal Revenue Service (IRS) announced a new compliance campaign to focus on the separate detach filing of…
Dormant foreign corporations not subject to complicated Form 5471 filing requirements
The reporting requirements for IRS Form 5471 are complex, including ‘category of filer’ and required schedules. However, very few taxpayers know that there are special simplified filing rules for a…
Beware: IRS Form 8938 Statement of Specified Foreign Financial Assets
…Single taxpayers/married filing separately: $50,000 on the last day of the year or $75,000 anytime during the year. Married filing jointly: $100,000 on the last day of the year or…
Complicated Form 5471 filing requirements simplified for dormant foreign corporations
The reporting requirements for IRS Form 5471 are complex, including ‘category of filer’ and required schedules. However, very few taxpayers know that there are special simplified filing rules for a…
AICPA Makes Useful Recommendations For International Forms 3520/3520
…to extend the due date for filing a Form 3520 by filing an extension (in the case of an individual, a Form 4868, Application for Automatic Extension of Time to…
Numerous Criminal Prosecutions of Taxpayers with Unreported Offshore Accounts
…guilty to filing a false tax return for the year 2008. Bhasin owned accounts at HSBC in India that, in 2008, were valued at approximately $8.3 million, and generated approximately…
Penalties for Not Filing Form 3520
The IRS requires a U.S. person receiving a gift from a foreign individual, corporation, partnership, or estate to report by filing Part IV Form 3520. Failure to file or late,…
New Favorable Court Decision: One penalty (not multiple) applies for late FBAR filing
…filing of a single accurate “Report of Foreign Bank and Financial Accounts” (FBAR) that includes multiple foreign accounts. The Boyd case holds that the IRS may impose only one non-willful…
Upcoming live video webinar: U.S.-India Tax Planning: Reporting Issues, Traps to Avoid, Tax Treaties, FTC, FACTA/FBAR Reporting, Passive Income
…accounts, contributions, and withdrawals. The extensive U.S. tax reporting requirements imposed on taxpayers with U.S. filing obligations are hovering over all these concerns. There are many complexities in filing individual income tax…
Helpful Non-willful FBAR penalty case decided by court
…Account) with respect to his foreign account, finding that he failed to make the required filings, he had no reasonable cause for that violation, and his constitutional objections were without…
Is First-Time Abatement Applicable In International Penalty Cases?
…was addressed to IRS Independent Office of Appeals employees focusing on international penalties and provides updated guidance regarding the appeals procedures for first-time abatement in international penalty cases. The memorandum…
Taxpayer Tips: Best Practices for U. S. Tax Court
…not in excess of $50,000, the taxpayer also has the option to choose to have the case conducted under the “small tax case” procedures. These procedures are simpler and less…
IRS Announces Key Milestone in FATCA Implementation; U.S. Begins Reciprocal Automatic Exchange of Tax Information under Intergovernmental Agreements
…to FATCA, the Foreign Account Tax Compliance Act. To achieve this, the IRS successfully and timely developed the information system infrastructure, procedures, and data use and confidentiality safeguards to protect…
Comments on IRS Form 3520 to Report Foreign Gifts
…come into compliance, the taxpayer should be exempt from penalty for all of the years in question under FTA. This will reduce the chilling effect on compliance and reporting as…
BE-10 Report: A New Overlooked International Reporting Form
The Bureau of Economic Analysis (BEA) is an agency of the U.S. Department of Commerce and is currently conducting a benchmark BE-10 survey which entails the filing of a BE-10…