The recent report from a government watchdog agency called the Government Accountability Office (GAO) shows how well the IRS attack on offshore tax evasion is coming. The GAO makes recommendations to the IRS, and the IRS pays attention. Those
Can I Disclose Issues to the IRS After the Tax Return Is Filed? This question is very important for our clients exploring silently disclosing previously unreported income on an amended income tax return. The general
Following the IRS’ successful 2009 and 2011 offshore voluntary compliance initiatives, tax professionals should expect an increase in IRS examination activity of taxpayers who did not enter into these compliance initiatives. Approximately 30,000 taxpayers entered
IRS Special Agents are employed by the Criminal Investigation Division (CID) which is the law enforcement arm of the Internal Revenue Service (IRS). Special Agents conduct tax investigations that are intended to result in criminal
The 2012 National Taxpayer Advocate (NTA) Annual Report to Congress criticized current IRS practices in the Offshore Voluntary Disclosure Program (OVDP) that hinder voluntary compliance by penalizing taxpayers who are entitled to a reasonable cause
When a taxpayer has a tax increase though a civil tax audit (or examination, in IRS terminology), a taxpayer has the right to appeal that increase administratively and through court, if unsuccessful administratively. For taxpayers
Last month, HSBC Holdings agreed to pay $1.92 billion in fines to U.S. authorities, which is the largest collective settlement in the Treasury Department’s history. The penalty assessment was based upon HSBC’s conduct in violation
Bank Leumi is urging its U.S. clients to disclose information about their accounts to U.S. authorities investigating Leumi and many other foreign banks over possible tax avoidance by Americans. In a December 16 letter Leumi
I just returned from the American Bar Association Section of Taxation’s annual National Institute on Criminal Tax Fraud in Las Vegas. A topic of discussion was the relatively new New Streamlined Filing Compliance Procedures for
Over the past several years our law firm has counseled hundreds of non-compliant U.S. taxpayers in the exploration of their legal options with respect to the Offshore Voluntary Disclosure Initiative programs. As a result, we
The Department of Justice continues to prosecute cases involving United States taxpayers who have failed to report their interests in offshore accounts. Most of the cases are for large offshore accounts, but they provide good guidance
When the IRS receives payment with amended tax returns for taxes, interest and penalties, the IRS may misapply the payment. This results in IRS notices. Reminiscent of the mistakes of the 2009 OVDP, the IRS
