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Part II – Six IRS Letters and Notices You Must Not Ignore by Edward M. Robbins, Jr.

Every year the IRS sends millions of letters and notices to taxpayers for a variety of reasons. Many of these letters and notices are for informational purposes only and do not need a taxpayer response.  Many more of these letters and notices are benign and can be dealt with simply, without having to call or … Continue reading Part II – Six IRS Letters and Notices You Must Not Ignore by Edward M. Robbins, Jr.

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New IRS Commissioner Nominated by President Obama

President Obama recently announced his nomination of John Koskinen as the next Commissioner of the Internal Revenue Service for the term expiring on November 12, 2017. President Obama stated, “John is an expert at turning around institutions in need of reform.  With decades of experience, in both the private and public sectors, John knows how to … Continue reading New IRS Commissioner Nominated by President Obama

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Professional Responsibility and the FBAR by Michel Stein

We applaud the Internal Revenue Service (“IRS”) for releasing information regarding professional responsibility and the Foreign Bank and Financial Accounts Reports (“FBAR”).  The FBAR reporting requirements have gain much attention in the past five years and have produced a whole host of ethical and legal concerns not historically considered by practitioners. There have been ongoing … Continue reading Professional Responsibility and the FBAR by Michel Stein

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PART I: Six IRS Letters and Notices You Must Not Ignore by Edward M. Robbins, Jr.

Every year the IRS sends millions of letters and notices to taxpayers for a variety of reasons. Many of these letters and notices are for informational purposes only and do not need a taxpayer response.  Many more of these letters and notices are benign and can be dealt with simply, without having to call or … Continue reading PART I: Six IRS Letters and Notices You Must Not Ignore by Edward M. Robbins, Jr.

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CAN THE FRAUD OF THE TAX PREPARER BE IMPUTED TO THE TAXPAYER? by Steve Toscher and Della Bauserman

Prior to 2001, the answer was generally “No.”  Today, the answer is unclear. In 1950, there were a series of cases, that all had similar facts, where the Tax Court addressed the issue of whether the fraud of the preparer could be imputed to the taxpayer for the purposes of the fraud penalty under IRC … Continue reading CAN THE FRAUD OF THE TAX PREPARER BE IMPUTED TO THE TAXPAYER? by Steve Toscher and Della Bauserman

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Reminder: 2012 FBAR Filing Due by June 30

If you had any interest in a foreign financial account at any time during calendar year 2012, you may have an obligation to file an FBAR by June 30, 2013! 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 … Continue reading Reminder: 2012 FBAR Filing Due by June 30

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DoJ Files Action to Collect Multiple 50% Civil FBAR Penalties in U.S.A. vs. Zwerner

Numerous 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 filing and reporting obligations. Many U.S. taxpayers are pursuing participation in the current IRS offshore voluntary disclosure program (the OVDP which began in 2012), modeled … Continue reading DoJ Files Action to Collect Multiple 50% Civil FBAR Penalties in U.S.A. vs. Zwerner

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Recissions of IRS OVDP Pre-Clearance Letters

Taxpayers participating in the IRS Offshore Voluntary Disclosure Program (OVDP – see www.irs.gov for OVPD information and guidance) generally agree to  an “FBAR-related” penalty (in lieu of all other potentially applicable penalties associated with a foreign financial account or entity) of 27.5% of the highest account value that existed at any time during the prior eight … Continue reading Recissions of IRS OVDP Pre-Clearance Letters

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IRS FBAR Voluntary Disclosure Program, Opt-Out Considerations and Taxpayer Interviews

The IRS has operated four offshore voluntary disclosure programs (OVDP) since 2003 offering various incentives for taxpayers to disclose their offshore financial accounts and pay delinquent taxes, interest, and penalties. As of December 2012, the combined OVDPs resulted in more than 39,000 disclosures by taxpayers and over $5.5 billion in revenues received.[i] Beyond revenue generation, … Continue reading IRS FBAR Voluntary Disclosure Program, Opt-Out Considerations and Taxpayer Interviews

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Form 8300: Reporting Domestic Currency Transactions

The IRS Small Business/Self-Employed (SB/SE) Division maintains an anti-money laundering (AML) territory manager in each of its 16 Areas, together with 33 AML compliance groups and approximately 350 full-time examiners. IRS Criminal Investigation’s Suspicious Activity Report (SAR) review teams in each of their 35 field offices focus on detecting money laundering activities as well as … Continue reading Form 8300: Reporting Domestic Currency Transactions

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New Filing Compliance Procedures for Non-Resident U.S. Taxpayers

The IRS recently announced a Streamlined Filing Procedure (SFP), that became effective September 1, 2012, intended to entice current non-residents and dual citizens who have not filed U.S. income tax and information returns to file their delinquent returns back into filing and reporting compliance. Since 2009, many non-residents began participating in various IRS offshore voluntary … Continue reading New Filing Compliance Procedures for Non-Resident U.S. Taxpayers

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IRS Provides Updated Guidance re FBAR Voluntary Disclosure Program

For years, the IRS has been pursuing – with mixed success – the disclosure of information regarding undeclared interests of U.S. taxpayers (or those who ought to be U.S. taxpayers) in foreign financial accounts. On June 26, 2012 the IRS released IR-2012-64/65 and updated Frequently Asked Questions (FAQs) providing updated guidance regarding the currently pending … Continue reading IRS Provides Updated Guidance re FBAR Voluntary Disclosure Program

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