The US Treasury Inspector General for Tax Administration (TIGTA), in two recent reports, said that the IRS collected more tax revenue in 2019 than in any other previous year but, at the same time, overlooked
Last week the IRS released a memorandum with new procedures for an “Updated Voluntary Disclosure Practice” impacting all voluntary disclosures. The new updated voluntary disclosure practice (VDP) is a game-changer for offshore voluntary disclosures for US persons
The Internal Revenue Service released new updated procedures for voluntary disclosures since the old Offshore Voluntary Disclosure Program (OVDP) closed on September 28, 2018. Last week, IRS deputy commissioner Kirsten Wielobob issued Interim Guidance Memo LB&I-09-1118-014,
An IRS CP 503 notice is a letter that the IRS sends out to individuals as a reminder and a means to collect on a tax debt balance. This letter is a final notice and
The cost of compliance for many people is growing. Those U.S. persons with bank accounts in foreign jurisdictions who have yet to come into compliance with U.S. tax filing requirements have very little time. In
An audit reconsideration is defined by the Internal Revenue Manual (IRM) as: the process the IRS uses to reevaluate the results of a prior audit where additional tax was assessed and remains unpaid, or a tax
Under Sec. 6212(a) the IRS can issue a statutory notice of deficiency, also known as a 90-day letter, when it determines a deficiency in an income or estate and gift tax liability. A 90-day letter
What you need to do If you want to challenge the deficiency determination, file a petition with the Tax Court. File your tax return immediately (no later than 90 days from the date of the
Taxpayers who are in the Offshore Voluntary Disclosure Program to report their overseas assets can request the favorable penalty structure under newly expanded streamlined compliance procedures without giving up the audit and criminal liability protection
12 years ago the IRS created the first-time penalty abatement administrative waiver (FTA), which allows typically compliant individual and business taxpayers to request abatement, or removal, of certain penalties that the IRS has assessed against them
The IRS’ Large Business & International division has issued a series of directives that streamline its information document request (IDR) process by establishing stricter deadlines and requiring the agency to issue highly specific information requests.
In a tax audit situations, the IRS only has a 3 year statute of limitations to assess additional taxes. If the IRS takes too long to initiate an audit, or the audit drags on too
