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Voluntary Disclosure – Benefits of Timely Filing Amended and Delinquent Tax Returns

Voluntary Disclosure. Practitioners often struggle with the issue of whether a taxpayer can avoid a criminal tax investigation by making a disclosure to the IRS.  A “voluntary disclosure” is generally the process of voluntarily reporting previously undisclosed income (or false deductions) through an amended return or the filing of a delinquent return. A taxpayer’s timely, … Continue reading Voluntary Disclosure – Benefits of Timely Filing Amended and Delinquent Tax Returns

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IRS Non-Filers Beware: Who’s That Knocking at Your Door ?

For numerous reasons, many taxpayers fail to timely file required U.S. income tax returns and associated reports. A “non-filer” is described as a taxpayer (or someone who ought to be a taxpayer) who does not file their return before the deadline to file the next year’s return. A “late filer” is taxpayer who misses the … Continue reading IRS Non-Filers Beware: Who’s That Knocking at Your Door ?

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AGOSTINO & ASSOCIATES NEWSLETTER – De Novo Review of Assessable International Penalties

AGOSTINO & ASSOCIATES –To download a few great articles prepared by our very close friends at the Law Firm of Agostino & Associates in Hackensack, NJ ( www.agostinolaw.com ), see the Agostino & Associates Newsletter https://doc-0g-a0-apps-viewer.googleusercontent.com/viewer/secure/pdf/3nb9bdfcv3e2h2k1cmql0ee9cvc5lole/a2e9d5ia6l9d8arb24i9qe55u5g1r2jr/1409675775000/drive/*/ACFrOgB3DcF0a_jTmvIpYCiuNKqO7L9fgn3s-OoYgXI80f841xzDJ5w3W4RQJIos9LXs1ctCT2z8v3FIziSDS2y-W6ct63hwuBzvEW_vnXAgbmb31pJpOwZuVMW1Ou8=?print=true DE NOVO REVIEW OF ASSESSABLE INTERNATIONAL PENALTIES By Frank Agostino, Brian D. Burton, and Lawrence A. Sannicandro    – Many taxpayers and … Continue reading AGOSTINO & ASSOCIATES NEWSLETTER – De Novo Review of Assessable International Penalties

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RECOMMENDATIONS FOR IRS TAX RETURN PREPARERS

All tax planning is not to be condemned. “It is no surprise that a knowledgeable tax attorney would use numerous legal entities to accomplish different objectives. This does not make them illegitimate. Unfortunately such ‘maneuvering’ is apparently encouraged by our present tax laws and codes.” [1] CIRCULAR 230 – Cir. 230 provides the regulations governing … Continue reading RECOMMENDATIONS FOR IRS TAX RETURN PREPARERS

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A CORNUCOPIA OF OVDP TAX FRAUD by EDWARD M. ROBBINS, Jr.

Has this happened to you? You are in your office toiling away in the tax trenches when a colleague down the street who works the offshore cases sends you an e-mail: “I’m sending over an OVDP client. He has a problem and I can’t represent him anymore.” Eventually the client sits in your office and … Continue reading A CORNUCOPIA OF OVDP TAX FRAUD by EDWARD M. ROBBINS, Jr.

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HIDDEN RESOURCES: IRS Audit Techniques Guides

Historically, IRS examiners were assigned to audit taxpayers in many different industries. On one day, an examiner audited a grocery store and on the following day the examiner may have audited a computer retailer or a medical doctor. As a result, experience gained in one audit did not significantly enhance the examiner’s experience for purposes … Continue reading HIDDEN RESOURCES: IRS Audit Techniques Guides

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Am I “Non-Willful” Under the IRS OVDP Streamlined Procedures ?

The IRS recently announced Streamlined Filing Compliance Procedures in an effort to encourage U.S. taxpayers to come into compliance with their reporting and filing requirements associated with varying interests in foreign financial accounts and assets.[i] The streamlined procedures require the filing of original or amended tax returns reporting not only for whatever foreign source income … Continue reading Am I “Non-Willful” Under the IRS OVDP Streamlined Procedures ?

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IRS Methods of Indirectly Determining Taxable Income

There are various audit and investigative techniques available to corroborate or refute a taxpayer’s claim about their business operations or nature of doing business. IRS audit or investigative techniques for a cash intensive business might include an examiner determining that a large understatement of income could exist based on return information and other sources of … Continue reading IRS Methods of Indirectly Determining Taxable Income

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FIRST TIME ABATE of IRS Penalties

The Internal Revenue Manual (IRM) contains a Penalty Handbook intended to serve as the foundation for addressing the administration of penalties by the IRS. It is the “one source of authority for the administration of penalties. . .”[1] and provides a “fair, consistent, and comprehensive approach to penalty administration.” As such, the IRM is often … Continue reading FIRST TIME ABATE of IRS Penalties

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OVDP & Streamlined Procedures: Expect the Unexpected!

The IRS recently announced Streamlined Filing Compliance Procedures in an effort to encourage U.S. taxpayers to come into compliance with their reporting and filing requirements associated with varying interests in foreign financial accounts and assets. The streamlined procedures require the filing of original (for non-residents) or amended (for residents) tax returns. Such tax returns must not … Continue reading OVDP & Streamlined Procedures: Expect the Unexpected!

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Critical Links – 2014 OVDP & Streamlined Filing Compliance Procedures

The IRS recently announced an expansion of the streamlined filing compliance procedures announced in 2012 and important modifications to the 2012 Offshore Voluntary Disclosure Program (OVDP). For eligible taxpayers residing outside the U.S., the revised Streamlined Filing Compliance Procedures provide that all penalties will be waived. For eligible taxpayers residing in the U.S., the revised … Continue reading Critical Links – 2014 OVDP & Streamlined Filing Compliance Procedures

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IRS OVDP OPT OUT vs. TRANSITION TO THE NEW STREAMLINED PROCEDURES?

The Internal Revenue Service recently announced significant changes in IR-2014-73[i] regarding their offshore voluntary compliance programs, providing new options to help both resident and non-resident U.S. taxpayers whose failure to disclose their offshore financial accounts was non-willful. The expanded 2014 streamlined procedures are available to a wider population of U.S. taxpayers living outside the country and, … Continue reading IRS OVDP OPT OUT vs. TRANSITION TO THE NEW STREAMLINED PROCEDURES?

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