Search Results for: irs appeal
IRS Investigating Employee Retention Credit (ERC) claims
The IRS continues to warn businesses not to fall for aggressive marketing or scams related to the ERC. Businesses should first check with their trusted tax professional before submitting an…
What Do Tax Lawyers Do?
…IRS places a tax lien against your property, selling assets can become impossible. A tax attorney can work with the IRS to release its lien on your property and find…
India and US signed FATCA Agreement Today
…registered on the IRS’s FATCA Registration Portal. The IRS has published a searchable list of financial institutions. The FFI List Search and Download Tool is located on the IRS’s FATCA…
Watch Out: Malta Pension Plans Become Listed Transaction
…underpayment of tax attributable to the listed transaction, plus $10,000. The IRS previously placed Malta personal retirement schemes on its “Dirty Dozen” list in July 2021. According to the IRS,…
Delinquent FinCen Form 114 (FBAR) Filings
…issue: IRS delinquent FBAR submission procedure: The IRS offers a new “delinquent FBAR submission procedure”, which is available if you properly reported on your U.S. tax returns, and paid all…
Specific Steps for Applying to the IRS Streamlined Foreign Offshore Procedures
If you are a US Person and not compliant for not properly reporting foreign accounts, assets, investments, and income to the IRS, you may have learned about Streamlined Procedures. If…
Global Enforcement of FATCA: Something to Worry About
…agreement directly with the IRS, provided that each FFI is registered with the IRS or is excepted from registration under the agreement or under IRS guidance. Allow FFIs established in…
Foreign Proprietorship: Form 8858 Filing Requirement
…procedure if the IRS has been in contact with you about the missing forms. If you are under a criminal or civil investigation from the IRS, you are disqualified from…
NJ Division of Taxation Offers Offshore Voluntary Compliance Initiative
…copy of the IRS acceptance letter into the IRS second offshore voluntary disclosure program and copies of the IRS documents reflecting the federal tax examination changes. Upon receipt and review…
NY Art Consultant Indicted for Filing False Tax Returns and Failing to File FBARs
…our partners at the IRS, will follow our investigations of U.S. tax law violations wherever they lead.” The United States IRS also announced “The use of offshore bank accounts to…
File a Protective Claim for Refund for Possible OVDP Opt Out Cases
…IRS has updated its appeals procedures for the resolution of contested foreign bank account reporting (FBAR) assessments outside the OVDP (Revised IRM 8.11.6). Protective Refund Claims: Tax advisors should be…
IRS Announces “Good Faith” 90 Day Extension of Voluntary Disclosure Deadline
The IRS said last week that it is making available to taxpayers a 90-day deadline extension to participate in the 2011 offshore voluntary disclosure initiative (OVDI). The extension would be…
New Law’s Reporting Requirements Make It Very Likely That the IRS Will Now Know About Your Foreign Account
…private equity and venture capital funds, etc.) must disclose their customers to the IRS. Institutions that do not agree to comply with the reporting requirements of FATCA will subject all…
Malta pension plans listed on “Dirty Dozen” list of “tax scams”
Last week, the Internal Revenue Service (IRS) placed certain Malta-based pension plan arrangements on its annual “Dirty Dozen” list of “tax scams.” In its recent news release, the IRS warns…
Argue for No Penalty and a Warning Letter for FBAR Violations
…would be sufficient to bring the individual into compliance, an IRS official recently said. Jason Kuratnick, IRS associate area counsel (Philadelphia), Small Business/Self-Employed Division, explained that the Office of Chief…
HSBC Bank Expects Significant Penalties from US Government for Violations
…HSBC India. HSBC said in a regulatory filing last night that it is cooperating with the US Department of Justice and the Internal Revenue System (IRS) in their probes into…
Opting-out or Opting-in of OVDI
The IRS last week explained fully the possibility of opting-out of the OVDI and taxpayers’ taking their chances with an IRS examination, particularly where the non-disclosure of assets or income…
In Addition to HSBC, Credit Suisse Also Being Investigated for Offshore Activities
…which is likely, it may be too late for U.S. taxpayers with undisclosed HSBC accounts to take advantage of the IRS Voluntary Disclosure Program for offshore accounts. The IRS says…
Beware of FATCA Letters
…personal details and information about their bank accounts to the IRS. The IRS compares this data with the FBAR, Form 8938 and other filings. If discrepancies are spotted, a tax…
New Extended Deadline for OVDI
…the full voluntary disclosure package of information. As part of this late news, the IRS issues a new FAQ #24.1, as well as revised FAQ #25.1. The IRS statement and…
What if You Missed the OVDI Deadline?
Although the OVDI program has expired, a U.S. taxpayer can still make a voluntary disclosure of foreign accounts pursuant to the IRS’s general voluntary disclosure policy. For over 50 years,…
2018 ABA COMMENTS ON THE OFFSHORE VOLUNTARY DISCLOSURE PROGRAM AND THE STREAMLINED PROGRAMS
We are members of the American Bar Association Section of Taxation, which on May 2, 2018 submitted comments to the IRS on the IRS Offshore Voluntary Disclosure Program (“OVDP”), the…
FBAR compared to Form 8938: Differences, Which to File, When to File, etc.
…submit Form 8938 and/or FinCEN Form 114 (Report of Foreign Bank and Financial Accounts) to the IRS. These forms are used by the IRS to keep track of your foreign…
FBAR statute of limitations court case ruling
…filed his federal income tax returns for 2006 through 2008 but did not report income earned on a foreign account he held. The IRS served a John Doe summons seeking…
50% Penalty for Taxpayers Who Hold Accounts at a Bank Under Investigation
…taxpayers. The modifications greatly eased penalties for people who were unaware of tax and disclosure requirements. At the same time, the IRS sharply increased the penalty for people in its…
Details of the Streamlined Domestic Offshore Procedures
…facts and reasons (generally on a signed attachment) why their conduct was non-willful. In September 2017, the IRS revised Form 14654 to require more disclosure. Now the IRS also instructs…
Parag Patel Esq. speaks at NJCPA Tax Seminar: “Under the IRS Microscope: International Tax Reporting Update” and “What Tax Professionals Should Know About Trusts and Estates”
Parag Patel Esq. will be a featured speaker at a virtual New Jersey Society of Certified Public Accountants (NJCPA) Webinar panel entitled “Under the IRS Microscope: International Tax Reporting Update”…
The New DIIRSP: I like the old better
…for not timely filing the information returns, are not under a civil examination or a criminal investigation by the IRS, and have not already been contacted by the IRS about…
OVDP Ineligibility Possibility Increases
Yesterday the IRS stated that taxpayers’ eligibility to participate in the OVDP could be terminated if the foreign institution where you have your account faces IRS action. Once the U.S….
How to Demonstrate Non-Willfulness Under The Streamlined Filing Compliance Procedures
…have different 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. Persuasive advocacy is required to affirmatively…