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Tag: Streamlined Filing Compliance Procedures

Are You Ready For New FATCA Enforcement in 2020?

2 January, 2020

Banks and certain other financial institutions located outside the United States that have U.S. account holders are scrambling to meet a looming IRS deadline. These institutions, known as foreign financial institutions, or FFIs, must achieve

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The IRS Large Business and International division (LB&I) has announced a new Loose Filed Forms 5471 compliance enforcement campaign

1 August, 2019

The new Loose Filed Forms 5471 targeted enforcement campaign was identified through LB&I data analysis and suggestions from IRS employees. IRS employees likely received many Loose Filed Forms 5471 that were not properly filed, as

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Details of the Streamlined Foreign Offshore Procedures (SFOP)

19 July, 2019

Many U.S taxpayers are unfortunately surprised to discover that they have a U.S. tax reporting obligation on financial accounts or assets held overseas. Once they discover their tax and reporting obligation, there are a number

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Details of the Streamlined Domestic Offshore Procedures

2 July, 2019

Many U.S taxpayers are unfortunately surprised to discover that they have a U.S. tax reporting obligation on financial accounts or assets held overseas. Once they discover their tax and reporting obligation, there are a number

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Federal District Court Holds that FBAR Penalties in Excess of $100,000 is Unlawful

4 June, 2018

Recently, the U.S. District Court for the Western District of Texas in U.S. v. Colliot, determined that an individual who repeatedly failed to timely file Form TD F 90-22.1, Report of Foreign Bank and Financial Accounts, commonly

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New FBAR Court Case Makes it Easier for Taxpayers to be Deemed Willful

21 April, 2018

There is a debate as to the “burden of proof” that must be met by the Internal Revenue Service (IRS) in asserting that an FBAR violation was “willful”.  This is significant because those who willfully

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IRS Passport Revocation or Denial for Unpaid Taxes

11 December, 2017

Two years ago, Congress passed Internal Revenue Code Section 7345. This law allows the Internal Revenue Service (IRS) to work with the US State Department to suspend and/or deny the passports of taxpayers with seriously delinquent

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IRS Announces New Investigative Units

7 November, 2017

In a press call on August 2, 2017, the Chief of the Internal Revenue Service’s (IRS) Criminal Investigation Division (“IRS-CI” or CID), John D. Fort, announced two new enforcement initiatives: a National Coordinated Investigations Unit

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New Court Case Limits the Reasonable cause exception to FBAR penalties

3 September, 2017

Taxpayers across the country rely on advice from their accountants and CPAs to meet the complicated requirements of the U.S. Tax Code. But a new case, Jarnagin v United States, in the U.S. Court of

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New IRS practice unit: “Substantial compliance” doctrine, international information return penalties

29 June, 2017

The IRS Large Business and International (LB&I) division last week publicly released a “practice unit” that addresses what the term “substantially complete” means with reference to international information return penalties, particularly Form 5471. The IRS recently

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U.S. Taxpayers at New Risk of Audit from OVDP Declines and Withdrawals Campaign

19 June, 2017

Last year, the US Treasury Inspector General for Tax Administration (TIGTA) released a report which assessed how well that IRS was managing the Offshore Voluntary Disclosure Program (OVDP). OVDP is one of the programs taxpayers

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IRS Announces new OVDP Declines-Withdrawals Campaign

23 February, 2017

Earlier this month, the IRS’ Large Business and International division released its list of 13 focus areas for issue- based examinations and concerns for compliance.   One of those areas involves the IRS Offshore Voluntary

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