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Implications of United States v. Horowitz: Reckless = Willful?

Search Results for: sfop/planning-for-tax-minimization/irs-streamlines-its-streamlined-offshore-procedures-with-more-user-friendly-forms

Implications of United States v. Horowitz: Reckless = Willful?

15 June, 2021

...because they did not mention the foreign accounts to their accountant and signed tax returns inaccurately denying the existence of any foreign bank accounts on signed tax returns.             This...

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The IRS’ Complex Statute of Limitations

13 June, 2021

...IRS collections officers what the IRS system has calculated as the statute of limitations for tax collection. The general rule is that the IRS must collect taxes within 10 years...

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Willful FBAR Penalties

10 June, 2021

...the IRS each year by filing a Report of Foreign Bank and Financial Accounts (FBAR). Taxpayers must file the FBAR annually and the last day to timely file is at...

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What to do After Receiving Notice CP 15 or CP 215 for Failure to Timely File Form 3520

28 May, 2021

...to report. Persuasive experienced legal advocacy will be very important. This appeal should include all relevant facts and documents supporting the taxpayer’s position. Once a taxpayer appeals, the IRS Appeals...

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Penalties for Not Filing Form 3520

26 May, 2021

...to file Form 3520, Notice CP 15 or CP 215 is sent to the taxpayer notifying the taxpayer which requires a timely response. If the taxpayer wishes to appeal the...

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Expect new aggressive IRS targeted enforcement next year.

27 April, 2021

...with increased tax enforcement. In fact, I recommend taxpayers get independent tax legal counsel to review complex tax returns (beyond the regular tax preparer). To schedule a free tax planning strategy...

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The big question on a tax increases is not “if” but “when”

23 April, 2021

...second half of 2021 after taxpayers’ reasonable reliance on the laws in their tax planning and transactions. I also predict the returning the estate tax exemption amount to pre-Trump levels...

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The Dreaded IRS Letter 6185: “We received information that you have a foreign account”

20 April, 2021

...in possession of records that identify taxpayers with transactions or accounts at offshore private banks. Soft letters are IRS correspondence to targeted taxpayers identifying tax noncompliance and passively seeking compliance....

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Increased IRS Enforcement Expected Against High-Income Taxpayers

7 April, 2021

...a taxpayer who either does not timely file a required tax return and timely pay a tax due for the delinquent return. If contacted by the IRS, the taxpayer should...

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New Favorable Court Decision: One penalty (not multiple) applies for late FBAR filing

25 March, 2021

...report these on her 2010 federal income tax return or disclose the accounts to the IRS.  In 2012, the taxpayer asked to participate in the IRS’s Offshore Voluntary Disclosure Program,...

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Parag Patel to be Speaker for Estate Planning at Practicing Law Institute’s NJ Basic CLE Marathon 2021

16 February, 2021

...attorneys practicing in estate planning matters seeking to learn about common estate planning techniques, including New Jersey-specific instruction and tax minimization. Topics to be covered include: Durable power of attorney...

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Parag Patel to be Speaker for Estate Administration at Practicing Law Institute’s NJ Basic CLE Marathon 2021

15 February, 2021

...attorneys practicing in Estate Administration and probate matters seeking to learn about probate procedures, including New Jersey-specific instruction and tax minimization. Topics to be covered include: * Managing the estate...

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