Search Results for: irs appeal
New offshore account disclosure law
…a charitable trust) IRS may treat the trust as having a U.S. beneficiary unless such person can demonstrate to the satisfaction of IRS that under the terms of the trust,…
Federal District Court Holds that FBAR Penalties in Excess of $100,000 is Unlawful
…criminal sanctions may outweigh this dollar issue. See OVDP FAQ 6 ). Finally, unless the IRS appeals and wins the case, it seems to me that until appropriate action is…
2016 US Dept of Justice (DOJ) Tax Division: FBAR penalty collection cases
…enforced collection would require a lawsuit in federal court. This limitation on the IRS’s ability to administratively collect the FBAR penalty should provide an inducement to the IRS to resolve…
ERC Disallowance Letters 105C Sent to Taxpayers
The IRS has notified over 20,000 taxpayers via IRS Letter 105C (Disallowance of Claim) that their claims for the employee retention credit are being disallowed because entities either did not…
How to Avoid Jail and Clean Up Tax Problems
…sent to the examination for review and examination. The taxpayer must cooperate with the IRS examiner or else the examiner can request that the IRS revoke its acceptance of the…
Forms 3520, 5471 and 5472 Penalty Relief
In IRS Notice 2022-36, the IRS granted relief from certain failure-to-file penalties and certain international information return penalties for most individual and business taxpayers who did not file tax returns…
Visited by IRS Special Agents?
IRS Special Agents are employed by the Criminal Investigation Division (CID) which is the law enforcement arm of the Internal Revenue Service (IRS). Special Agents conduct tax investigations that are…
What is the U.S. tax on Inheritances from a Non-U.S. Person to U.S. Person?
…receive as a gift from overseas? Unlimited. What IRS tax form do I need to file if I received a gift or inheritance from a foreigner? IRS Form 3520. Although…
With No More Amnesty Program: Explore the IRS’s Traditional Voluntary Disclosure program
…forward through the IRS’s traditional Voluntary Disclosure program. Like the OVDI, the traditional Voluntary Disclosure program provides taxpayers an opportunity to come forward and potentially avoid criminal prosecution. The IRS…
IRS Targets Puerto Rican Residency Transactions
…campaigns and added it to the IRS annual “Dirty Dozen” list. We expect the IRS to criminally and civilly target taxpayers who claimed the Puerto Rico Act 2022 benefits and…
Recent Court Decision Shows Risks of IRS Streamlined Filing Compliance Procedures
…estate (Taxpayer) attempted to become compliant through the IRS’s Streamlined Domestic Offshore Procedures (“SDOP”). The IRS flagged the submission and assessed the maximum willful FBAR penalties against the Taxpayer because…
HSBC Expected to Disclose Account Holders Names
…has filed a petition with the court to allow the IRS to serve a John Doe summons on HSBC that authorizes the IRS to obtain information on possible tax fraud…
HSBC Client Pleads Guilty to Conspiring to Hide Indian Accounts From IRS
…will disclose its customer list, which will become a target list for the IRS. HSBC customers are strongly recommended to seek legal counsel immediately and consider entering the IRS’ new…
National Taxpayer Advocate Fights for FTA Penalty Relief from the IRS
…the last three years, Collins wrote that TAS will be placing heavy emphasis on working with the IRS to improve the processing of tax returns and taxpayer service generally. Among…
2011 Offshore Voluntary Disclosure Initiative (OVDI)
…IRS How to Make a Voluntary Disclosure from IRS. Our law firm can assist. 2011 OVDI General Information from IRS 02.08.2011 IRS News Release introducing the 2011 OVDI Commissioner Douglas…
New FBAR Court Case Makes it Easier for Taxpayers to be Deemed Willful
There is a debate as to the “burden of proof” that must be met by the Internal Revenue Service (IRS) in asserting that an FBAR violation was “willful”. This is…
Hiding Money or Income Offshore Among the “Dirty Dozen” List of Tax Scams for the 2015 Filing Season
…this initiative alone. The IRS conducted thousands of offshore-related civil audits that have produced tens of millions of dollars. The IRS has also pursued criminal charges leading to billions of…
IRS Releases Training Documents on Offshore Voluntary Disclosure Program
…material used in training IRS personnel in the Offshore Voluntary Disclosure Program, determining program penalties and instructing IRS employees about the program. The purpose of the OVDP is for individuals…
The IRS Large Business and International division (LB&I) has announced a new Loose Filed Forms 5471 compliance enforcement campaign
The new Loose Filed Forms 5471 targeted enforcement campaign was identified through LB&I data analysis and suggestions from IRS employees. IRS employees likely received many Loose Filed Forms 5471 that…
New IRS internal procedure guidance for Streamline Filing Compliance Procedures
The IRS has published new IRS internal procedure guidance with IRM changes dated 8/13/14. The guidance is numbered WI-21-0814-1244 and titled “Streamline Filing Compliance Procedures for Accounts Management International IMF”….
How to Respond to an IRS CP3219N Notice of Deficiency (90-day letter)
…letter (a preliminary notice of unagreed deficiency that gives the taxpayer an opportunity to request an administrative review by the IRS’s Office of Appeals); or The taxpayer asks for the…
Received a FATCA Letter from Your Foreign Bank?
…odd or new to you but lately banks everywhere want to know if you are compliant with the IRS. Basically, the entire world is helping the IRS. Since January of…
IRS Announces Penalty Mitigation for Smaller US Taxpayers Living Abroad
…not force everyone through the OVDI/OVDP programs. Yesterday, the IRS today announced a plan to help U.S. citizens residing overseas, including dual citizens, catch up with tax filing obligations and…
Appeals of penalties imposed during the Offshore Voluntary Opt-Out
…appeals they likely will be handled as Appeals Coordinated Issues to assure national consistency. An Appeals Coordinated Issue is a national IRS strategy whereby the National IRS Office has removed…
Latest Guilty Plea for an Another HSBC Offshore Bank Accountholder
…to report it, or the interest income that accrued in the HSBC Bank Bermuda account, to the IRS. In so doing, Schiavo deprived the IRS out of $40,624 in taxes….
IRS Reduces Administrative Burden (for the first time) of Filing Some Forms 3520 and/or Forms 3520-A
A Revenue Procedure just released by the U.S. Internal Revenue Service (IRS) provides U.S. persons an exemption from the information reporting requirements for certain tax-favored foreign retirement and non-retirement savings…
Parag Patel Esq. Speaks at NJCPA Seminar on”Employee Retention Credit Audit Issues: Surviving IRS Scrutiny”
Parag Patel Esq. was a featured speaker at a New Jersey Society of Certified Public Accountants (NJCPA) Seminar entitled “Employee Retention Credit Audit Issues: Surviving IRS Scrutiny”. You may email…
Solution: Streamlined Domestic Offshore Procedures
…may be made on one of the following forms initially released by the IRS: For U.S. taxpayers residing in the U.S. – IRS Form 14654: Certification by U.S. Person Residing…
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…
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…