Search Results for: streamlined filing compliance procedures
Increased IRS Enforcement Expected Against High-Income Taxpayers
…first report, concerning IRS compliance trends and enforcement activities, TIGTA said that the IRS collected $3.6 trillion in total revenue, more than any year previous and $99.1 billion more than…
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…
Significant FBAR Penalties Upheld by Court
…error was a common mistake for OVDP applicants to make in the early stages of the program. However, the IRS considered this action to amount to willful non-compliance and assessed…
Watch Out for PFIC Status
…be used to offset capital gains on other investments. Due to the Foreign Account Tax Compliance Act (FATCA), which forces every single financial institution to submit information on their American…
Pandora’s Box Has Opened: Pandora Papers
…for non-compliance. The penalties for FBAR noncompliance are higher than the tax penalties ordinarily imposed for delinquent taxes. For non-willful violations it is $10,000 per account per year going back…
New Form Updates for Foreign Accounts
The government has made a few recent form updates regarding the filing requirements for the following forms: FinCEN Form 114 (Report of Foreign Bank and Financial Accounts) – automatic…
Quiet or Silent Disclosure Commentary from the Government Accountability Office
…prior years’ returns. These taxpayers would also likely disclose the existence of the accounts by filing FBARs for the current calendar year. This filing would appear similar to the opening…
The IRS’ Complex Statute of Limitations
…of the date of assessment. The assessment date is the date of the filing of the return or the date tax liabilities are entered as assessments in the IRS’s records…
How to Limit a Executor’s Personal Liability for Taxes
…deficiency notices went to the wrong address. Also, the instructions to Form 56 state that the filing of a Form 56 when your PR is discharged will “relieve [the PR]…
The Strange Case of U.S. v. Hughes: Willful and Non-Willful (at the Same Time?)
…the FBAR filing requirements before filing her 2010 and 2011 tax return as there was no Schedule B included with her 2010 and 2011 returns. Thus the court held for…
How to Benefit from Tax Treaties
…not filing this form when you are supposed to: you can be fined up to $1,000 for each year you failed to report your treaty position. How do I claim…
Probate of Estates in New Jersey
…differ from case to case, but the following order generally applies: 1. Filing the will and petition at the surrogate court in order to be appointed executor or personal representative….
Beware of Overlooked Common Overseas Tax Forms
…114: This form is independent of the tax return and a separate filing requirement. The FBAR applies to any U.S. person who owns, has beneficial interest or signature authority over…
How to Respond to an IRS CP3219N Notice of Deficiency (90-day letter)
…one response to a Notice of Deficiency is permitted: filing a petition in the U.S. Tax Court clerk’s office in Washington, D.C. Taxpayers have a statutory 90-day window from the…
The questions most frequently asked about probate in New Jersey.
…consent of the others may obtain an Affidavit of Heir in lieu of filing a formal Administration. 5) b. What is the procedure in a small estate without a Will…
For Tax Professionals: A Guide to the IRS’s Voluntary Disclosure Practice
…and income: “quiet disclosure” or “noisy disclosure.” Quiet disclosure involves simply filing amended returns with the appropriate IRS service center and filing in Detroit the necessary FBAR forms that disclose…
Method to Cure Delinquent or Incomplete Foreign Information Returns Without Penalties
…a possible reduction of any applicable foreign tax credits. FAQ No. 17—FBAR Filing Failures Related to Foreign Financial Accounts FAQ No. 17 establishes an automatic waiver of the reporting penalties…
New Extended Deadline for OVDI
Last week, late on Friday afternoon, August 26, 2011, the IRS issued a statement indicating that the due date for filing 2011 Offshore Voluntary Disclosure Initiative (OVDI) requests has been…
What Do Tax Lawyers Do?
…court if necessary. Delinquent Tax Returns: Filing outstanding tax returns allows you to bring your account with the IRS current, but filing late can also lead to substantial interest fees…
NJ Contractor Charged with Criminal Tax Evasion for Unreported Checks
…four counts of corporate tax evasion, two counts of filing false corporate tax returns, and two counts of failing to file corporate tax returns. According to documents filed in this…
Powerful Post-death Planning Strategies for Trusts and Estates
…made by strategically filing Form 8855 with the Form 1041. This election can be made even if there are no income-producing probate assets in the estate. 3. 65 Day Election…
New Portability Election Extension Prevents Lost Estate Tax Exemption
…of whether a return would otherwise be due. Under Rev. Proc. 2022-32, estates filing estate tax returns solely to make the portability election (a portability-only return) have far more time…
The IRS Needs Help
…high number of returns needed manual processing this year, Erin Collins, the national taxpayer advocate, said in the report. At the end of this year’s filing season, the IRS had…
Are Trusts Required to Report under the Corporate Transparency Act (CTA)?
Generally, the answer is no. Starting January 1, 2024, the Corporate Transparency Act (CTA) will require most U.S. corporations, LLCs, and other legal entities formed through state filings or foreign…
Top 9 Most Expensive Medicaid Mistakes
…order). There are many options that our firm can advise depending upon your situation. 5. Filing an application for Medicaid too early. The proper timing of an application for Medicaid…
New Court Case Limits the Reasonable cause exception to FBAR penalties
…Report of Foreign Bank and Financial Accounts (FBAR) is not a tax form. Its filing is not required by the Internal Revenue Code. It is required by Title 31 of…
New IRS Relief for Taxpayers Experiencing COVID-related Difficulties
…below relief: · The IRS is highlighting reasonable cause assistance available through IRS procedures for failure to file, failure to pay and failure to deposit penalties. First time abatement (FTA)…
National Taxpayer Advocate Identifies OVDP Program as a Serious Problem
…a few situations in which a taxpayer could opt out without penalty. In addition, on September 1, 2012, it established a Streamlined Nonresident Filing Initiative that allows certain nonresidents to…
Answers to Common Questions for IRS CP3219N Notice of Deficiency (90-day letter)
…Tax Court has simplified procedures for taxpayers whose amount in dispute, including applicable penalties, is $50,000 or less per tax year. You can find these simplified small tax case procedures…
New York State Bar Association Proposes OVDI Changes to IRS
…procedures refer to taxpayers who have not made voluntary disclosures, taxpayers and practitioners have expressed concern that taxpayers who opt out of a voluntary disclosure program will face the same…