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IRS Changes Streamlined OVDP Reducing FBAR Penalty Exposure!

U.S. taxpayers with previously undisclosed interests in foreign financial accounts and assets continue to analyze and seek advice regarding the most appropriate methods of coming into compliance with their U.S. filing and reporting obligations. Many are pursuing participation in the IRS offshore voluntary disclosure program (the OVDP, which began in 2012 – modeled after similar … Continue reading IRS Changes Streamlined OVDP Reducing FBAR Penalty Exposure!

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IRS Makes Major Changes to Offshore Voluntary Disclosure Program !

The Internal Revenue Service announced major changes in IR-2014-73 regarding their offshore voluntary compliance programs, providing new options to help both taxpayers residing overseas and those residing in the United States. The changes are anticipated to provide thousands of people a new avenue to come into compliance with their U.S. tax obligations. The changes include … Continue reading IRS Makes Major Changes to Offshore Voluntary Disclosure Program !

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Reminder: 2013 FBAR Filing Due by June 30, 2014

U.S. persons having a financial interest in or signature authority over a foreign financial account, including a bank account, brokerage account, mutual fund, trust, or other type of foreign financial account may be required by the Bank Secrecy Act to report their interest in the account to the IRS by electronically filing by June 30, … Continue reading Reminder: 2013 FBAR Filing Due by June 30, 2014

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Zwerner: Jury Determines 150% FBAR Penalty Applies – Excessive Fines Clause to the Rescue??

U.S. taxpayers with previously undisclosed interests in foreign financial accounts and assets continue to analyze and seek advice regarding the most appropriate methods of coming into compliance with their U.S. filing and reporting obligations. Many are pursuing participation in the current IRS offshore voluntary disclosure program (the OVDP which began in 2012), modeled after similar … Continue reading Zwerner: Jury Determines 150% FBAR Penalty Applies – Excessive Fines Clause to the Rescue??

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PROTECTING PRIVILEGES DURING AN IRS EXAMINATION

A better-equipped IRS has been able to ferret out potentially sensitive issues in a manner often compromising the relationship between a taxpayer and his own tax representative. If there are potentially sensitive issues, the taxpayer should be interviewed by counsel to determine whether there is a need to fully preserve potentially privileged information. In turn, … Continue reading PROTECTING PRIVILEGES DURING AN IRS EXAMINATION

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IRS PROTECTIVE CLAIMS FOR REFUND by EDWARD M. ROBBINS, Jr.

If the resolution of a tax refund claim is contingent on future events and may not be determinable until after the time period for filing a claim for refund expires, practitioners can file a protective claim for refund on behalf of the taxpayer. A protective claim can be either a formal claim or an amended … Continue reading IRS PROTECTIVE CLAIMS FOR REFUND by EDWARD M. ROBBINS, Jr.

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ERRONEOUS REFUNDS AND CREDITS by Edward M. Robbins, Jr.

If the Internal Revenue Service makes an error in issuing a refund, it can recover the amount incorrectly refunded by filing a suit for erroneous refund. Section 7405[1] provides the Service with the ability to recover erroneous refunds within two years of payment. The two-year period can be extended to five years if any part … Continue reading ERRONEOUS REFUNDS AND CREDITS by Edward M. Robbins, Jr.

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U.S. Seeks FBAR Related Forfeiture of $12 Million

U.S. taxpayers with previously undisclosed interests in foreign financial accounts and assets continue to analyze and seek advice regarding the most appropriate methods of coming into compliance with their U.S. filing and reporting obligations. Many are pursuing participation in the current IRS offshore voluntary disclosure program (the OVDP, which began in 2012 – modeled after … Continue reading U.S. Seeks FBAR Related Forfeiture of $12 Million

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JUST RELEASED: Hot Audit Issues for the California FTB !!

The California Franchise Tax Board (FTB) just released the list of “hot” audit issues they are encountering in the process of examining returns filed by California taxpayers. The FTB is responsible for administering two of California’s major tax programs: Personal Income Tax (PIT) and the Corporation Tax. The FTB regularly receives and processes more than … Continue reading JUST RELEASED: Hot Audit Issues for the California FTB !!

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Virtual Currency Constitutes Taxable Property for U.S. Federal Tax Purposes

The IRS recently released guidance on the U.S. federal tax implications of transactions in, or transactions that use, virtual currency, such as Bitcoin.[1] For tax purposes, “gross income” is defined as “all income from whatever source derived”, including interest income, gains from dealings in property, and compensation paid for services, whether furnished by the taxpayer … Continue reading Virtual Currency Constitutes Taxable Property for U.S. Federal Tax Purposes

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IRS FBAR OVDP Opt-Out Interview Questions Revealed !

For more than a year, numerous taxpayers with previously undisclosed interests in foreign financial accounts and assets have been seeking participation in the current IRS offshore voluntary disclosure program (the OVDP) which began in 2012, modeled after similar programs in 2009 and 2011. Taxpayers participating in the OVDP generally agree to file amended returns and … Continue reading IRS FBAR OVDP Opt-Out Interview Questions Revealed !

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IRS Internal IDR Training Materials Revealed !

The IRS Large Business & International (LB&I) Division recently issued three recent Directives relating to the issuance and enforcement procedures regarding Information Document Requests (IDRs)(See previous Blog “NEW IRS LB&I Revised IDR Enforcement Process“).[1] LB&I is generally responsible for examinations of wealthy individuals, closely held entities and partnerships, corporations, and S-corporations with assets greater than $10 … Continue reading IRS Internal IDR Training Materials Revealed !

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