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IRS Updates Procedures for Voluntary Disclosures

Contents1 IRS Updates Voluntary Disclosure Practice2 What is IRS Voluntary Disclosure?3 Steps for Making a Voluntary Disclosure Under the Revised Guidelines3.1 1. Make a pre-clearance request3.2 2. Submit required voluntary disclosure documents3.3 3. Go through an examination4 Disclosure Periods and Examination Process5 Penalty Calculation6 Who Needs to Use the Voluntary Disclosure Practice? IRS Updates Voluntary … Read more

IRS Includes FATCA in 5 New Compliance Campaigns

Contents1 IRS Adds FATCA as a Compliance Campaign2 FATCA Filing Accuracy3 Individual Foreign Tax Credit (Form 1116)4 Individual Foreign Tax Credit Phase II5 Foreign Earned Income Exclusion Campaign6 1120-F Delinquent Returns Campaign7 Swiss Bank Program Campaign8 Nonresident Alien Schedule A and Other Deductions9 NRA Tax Credits10 F3520/3520-A Non-Compliance and Campus Assessed Penalties11 Forms 1042/1042-S Compliance12 … Read more

IRS Evaluates Crytocurrency Taxable Events

IRS Evaluates Crytocurrency Taxable Events At a recent conference, the IRS opened up about its cryptocurrency compliance efforts. To combat tax evasion from those engaged in cryto trading, the IRS has created cyber units, called CCUs. The hub is in Los Angeles, and agents are posted in Las Vegas, Denver, Seattle, Phoenix, and Dallas. IRS … Read more

Estates and FBAR Penalties

Contents1 Court Finds Representative of Estate Liable for Deceased’s FBAR Penalties2 Facts3 Court’s findings4 Voluntary disclosure options for estates Court Finds Representative of Estate Liable for Deceased’s FBAR Penalties The Court in United States v. Schoenfeld (M.D. Fla. 3:16-cv-1248-J-34PDB) finds that a deceased taxpayer’s FBAR civil penalty liabilities are collectible from his estate’s beneficiary. Facts Steven Schoenfeld, … Read more

FATCA Conviction for Bank Executive

Contents1 First Ever FATCA Conviction with Bank Executive Enabler’s Plea2 Foreign Account Tax Compliance Act (FATCA)2.1 Foreign financial institutions2.2 Individuals3 Exchange of Information Pursuant to Income Tax Treaties and Tax Information Exchange Agreements4 Deferred Prosecution Agreements5 What should non-compliant taxpayers do? First Ever FATCA Conviction with Bank Executive Enabler’s Plea The DOJ has recently secured … Read more

IRS Reminds Taxpayers of OVDP Ending

IRS Reminds Taxpayers of OVDP Ending and Hints at Updated Procedures Earlier this year the IRS announced that the OVDP would end on September 28th and the IRS issued a reminder to taxpayers last week of the program ending. More importantly the IRS states that it will maintain a pathway for such taxpayers to come … Read more

Late Filed Foreign Earned Income Exclusion

Contents1 Foreign Earned Income Exclusion – Late Elections2 Facts3 Foreign earned income exclusion – timely filing requirement4 Analysis Foreign Earned Income Exclusion – Late Elections Can the foreign earned income exclusion be elected on a late-filed return? Redfield v. Comm’r, T.C. Memo 2017-71 (T.C. April 26, 2017) answers this question. Facts Below are the facts … Read more