Search Results for: irs appeal
Start or review an “Accountable Plan”
Accountable Plans, established under IRS Reg. Section 1.62-2(c)(4), are important tools to help a business optimally classify expenses paid to employees without fear of the payments being treated as taxable…
IRS Issues Reminders for FBARs and other International Requirements
…of those assets exceeds certain thresholds. See the instructions for this form for details. IRS Reporting for Canadian Retirement Accounts: The IRS eliminated a special annual reporting requirement that applied…
IRS Official Announces New Focus on Offshore Assets in Indian Banks
Reporting on a California State Bar Tax Section Meeting, Tax Notes reports that the IRS will soon (as early as the week of 11/11/13) ) “begin examining U.S. taxpayers suspected…
HSBC officially provides information on clients having accounts in India to the US Department of Justice and IRS
…federal income taxes. In April 2011, HSBC Bank USA received summons from the Internal Revenue Service (IRS) asking the entity to produce records with respect to US-based clients of an…
IRS Provides Form 5471 Information-Filing Relief For Dormant Foreign Corps.
…the way for the IRS to prevent the disguised accumulation or tax deferral of funds. Filing an IRS Form 5471 is difficult and bad news for most shareholders of dormant…
Foreign bank account reports (FBARs) and the 2011 Offshore Voluntary Disclosure Initiative (2011 OVDI)
…and what is considered to be a “foreign financial account” that must be reported on an FBAR. In addition, the IRS recently announced a new offshore voluntary disclosure initiative that…
FATCAts
…FBAR is also a focus of the 2011 OVDI, which is the only IRS-approved method for eligible Americans with unreported offshore income and assets to ‘regularise’ their US tax affairs.…
Forms 5471, 5472, 3520 Partial Penalty Relief Still Available for 2019 and 2020 Returns
…Relief Still Available The IRS declined to extend the filing period or expand relief to the forms listed by the AICPA. In a statement, IRS Commissioner Chuck Rettig said the IRS understood…
IRS Announces new OVDP Declines-Withdrawals Campaign
Earlier this month, the IRS’ Large Business and International division released its list of 13 focus areas for issue- based examinations and concerns for compliance. One of those areas involves…
New Webinar: Resolving International Tax Compliance Disputes: FBAR Controversy, Penalties, Appeals, Form 3520/3520-A, Form 5471
…audits and IRS examinations FBAR controversy Administrative appeals District court and U.S. Court of Federal Claims litigation Evolution of IRS “non-willful” standard Best practices for tax counsel Benefits The panel…
Taxpayer Tips: Best Practices for U. S. Tax Court
…tax case may not be appealed to a Court of Appeals by the IRS or the taxpayer. Low-income taxpayers should also be aware that low-income tax clinics exist in almost…
New law complicates US Passport issuance
…an IRS offer in compromise, an appeal against a levy (such as a Collections Due Process Hearing), or are protected under Innocent Spouse Relief. Americans traveling for humanitarian reasons will…
Fantastic Recommendations for Form 3520
…Information Return of Foreign Trust With a U.S. Owner. Specifically, we suggest that the Independent Office of Appeals (Appeals) provide Appeals Case Memoranda (ACMs) where Appeals fully abates penalties relating…
IRS Releases FAQs for the Delinquent International Information Return Submission Procedures
The IRS recently released frequently asked questions for the Delinquent International Information Return Submission Procedures (available here). The IRS now states that these procedures are available to taxpayers even if…
New Report: Delinquent Taxpayers Could be Identified at US Border Crossings
…FATCA, which will require foreign financial institutions to begin reporting on the holdings of U.S. taxpayers to the IRS or else face stiff penalties of up to 30 percent on…
Beware IRS Forms W-8
Over the past few months we received many inquiries from clients and parties asked by companies to complete IRS Form W-8. Beware Form W-8 is generally filled out by foreign…
Major changes to IRS offshore voluntary compliance programs
Many clients are asking our office about the new compliance solutions to clean up past errors in disclosing foreign assets. In June 2014, the IRS announced major changes to its…
The Tax Heat is On
At the recent American Bar Association meeting held on January 29, 2016, the acting Attorney General for the tax division disclosed that the IRS and US Department of Justice are…
Foreign Gift Received: Form 3520 Penalties Eliminated in New Court Case
…are assessed. Wrzesinski appealed and even provided a letter from his accountant acknowledging the incorrect advice, but IRS appeals only abated 80% of the penalties based on the ‘Hazards of…
Top 5 tax fraud recoveries in 2022
…conviction on charges that he caused more than $62 million in losses to the IRS and PPP – over $19 million in losses to the IRS, and over $43 million…
No More Delays for FATCA: Get Ready for Disclosure
…and capital payments, according to the IRS. In IRS Notice 2013-43 “Revised Timeline and Other Guidance Regarding the Implementation of FATCA”, the IRS indicates that withholding agents generally will be…
One Month Countdown: The Deadline is Nearing for U.S. Taxpayers with Undisclosed Accounts to Come Forward
…by impeding the IRS. 30% Potential payout under the IRS Whistleblower Program as a percent of the amount collected as a result of your tip. $206M Amount collected under the…
Secret Swiss Bank Accounts are No Longer Secret
…2008, the IRS received authorization from the U.S. District Court in Miami to serve UBS with a“John Doe” summons, ordering the bank to deliver records that would provide the IRS…
Substantially Completed Form 5471 is Required to be Filed
IRS has recently released a new International Practice Unit (IPU) providing guidance to its examiners on the monetary penalties applicable if certain categories of U.S. shareholders fail to comply with…
How to Stretch Your IRA Into a Family Fortune
…Surprise: The life expectancies that govern mandatory IRA distributions as given in IRS tables are not actual life expectancies. The IRS life expectancies are much longer than actual average life…
Quarantine Tips for Tax Savings
…may continue. Any clients with current or pending audits can expect a significant slowdown. IRS Collection activities stopped: The IRS will suspend liens, levies, and seizures until at least July…
Large Penalties: Form 5471 Information Return of U.S. Persons With Respect to Certain Foreign Corporations
…in significantly more penalty assessments. The IRS sends taxpayers a CP 215 notice when it systemically assesses a late-filed Form 5471 penalty. Taxpayers can request that the IRS remove the…
The IRS publishes new proposed regulations for tax on transfers from covered expatriates
The IRS published new proposed regulations last week regarding the tax on gifts and bequests from covered expatriates last week. Section 2801 basically provides that if a U.S. citizen or…
2009 Tax Update
…are helpful when deciding how detailed your records need to be. Record Keeping for individuals http://www.irs.gov/pub/irs-pdf/p552.pdf Starting a business and keeping records http://www.irs.gov/pub/irs-pdf/p583.pdf Travel, Entertainment, Gift, and Car Expenses http://www.irs.gov/pub/irs-pdf/p463.pdf…
Bank Leumi: Another Foreign Bank Recommends the IRS Voluntary Disclosure Program
…Under the voluntary disclosure program, Americans can tell the IRS about undisclosed income from offshore accounts, and in return possibly get reduced fines and penalties. About 38,000 Americans have taken…