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The IRS Whistleblower Program: Making Money the Old Fashioned Way!

The IRS Whistleblower Office processes financial awards to people who provide information about the tax indiscretions of others. If the IRS uses information provided by the whistleblower, based on recently finalized Treasury Regulations the whistleblower can receive up to 30 percent of the additional tax, penalty and other amounts collected or refund denied! Statutory Limitations. … Continue reading The IRS Whistleblower Program: Making Money the Old Fashioned Way!

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Practice Tips From the Tax Trenches

Although often struggling with deadlines and sometimes recalcitrant clients, a tax practice should be an enjoyable, rewarding experience. Tax practitioners provide their clients with an objective, knowledgeable review of financial information that is ultimately presented to the government in the form of a tax or information return. If the client has provided timely, complete responses … Continue reading Practice Tips From the Tax Trenches

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FBAR Offshore Voluntary Disclosure Initiative (OVDI)

Taxpayers who have failed to report earnings on foreign bank accounts have until August 31, 2011 to do so without imposition of criminal penalties and with reduced civil penalties.  The reduced penalties apply to taxpayers who comply with the Internal Revenue Service’s Offshore Voluntary Disclosure Initiative (2011 OVDI), but only if the taxpayers do so … Continue reading FBAR Offshore Voluntary Disclosure Initiative (OVDI)

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

The IRS continues to enhance its ongoing enforcement efforts and expedited reporting between the IRS and the state taxing agencies will have a significant future impact on taxpayers who, for whatever reason, have failed to timely file their tax returns. The government can better identify taxpayers who have underreported or not reported income or have otherwise … Continue reading Non-Filers Beware: Who’s That Knocking at Your Door ?

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Examining the FBAR / Offshore Account Information Document Request (IDR)

Questions regarding the depth of an offshore account examination for those who, for whatever reason, did not participate in the 2009 OVDP or the 2011/2012 OVDI are now beginning to be answered in various IRS examinations around the country. A voluntary disclosure would not likely be considered timely following receipt of a notice of an … Continue reading Examining the FBAR / Offshore Account Information Document Request (IDR)

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IRS Voluntary Disclosure Practice

Since 1952, practitioners are unaware of any situation where the IRS has referred a timely, truthful and complete voluntary disclosure to the Department of Justice for criminal prosecution. A truthful, timely and complete voluntary disclosure is a factor considered in the IRS decision re a possible criminal prosecution referral to the U.S. Department of Justice. … Continue reading IRS Voluntary Disclosure Practice

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Overview of FBAR Reporting Requirements

U.S. citizens and residents are taxed on their worldwide income, subject to certain very specific exemptions, whether they live inside or outside of the United States. Foreign income must be reported on a U.S. tax return whether or not the person receives a Form W-2, Wage and Tax Statement, a Form 1099 (information return) or … Continue reading Overview of FBAR Reporting Requirements

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Qualified Amended Returns Can Eliminate Accuracy Related Tax Penalty

Improved tax compliance requires taxpayers (and those who ought to be taxpayers) to voluntarily come into compliance. When errors are discovered in a filed return, tax practitioners often pave the road to compliance through assurances that the tax-equivalent of water-boarding is not a typical government response to receipt of an amended return. Some assurances are … Continue reading Qualified Amended Returns Can Eliminate Accuracy Related Tax Penalty

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FOIA Requests: A Look Into the IRS Examination File

Practitioners should consider submission of a Freedom of Information Act (FOIA)[i] request to the IRS following the unagreed resolution of every tax examination. Although not always a wealth of information, the government response to a FOIA request will provide insight into why the examining agent made certain adjustments and asserted penalties. It will also help … Continue reading FOIA Requests: A Look Into the IRS Examination File

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IRS Global High-Wealth Industry Group: Evaluation of an IRS Wealth Squad IDR

The IRS Large Business and International Division (LB&I), formerly known as the Large & Mid-Sized Business Division, recently formed a new Industry Group known as the Global High-Wealth Industry Group, commonly referred to as the “Wealth Squad.” The purpose of the Wealth Squad is to bring together an IRS team of specialists to coordinate the … Continue reading IRS Global High-Wealth Industry Group: Evaluation of an IRS Wealth Squad IDR

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Basic Audit Techniques: Taxpayer Interviews

Requests to interview the taxpayer and return preparer during an otherwise normal IRS examination have become somewhat common. During an examination where the government is in possession of potentially incriminating evidence, such requests are routine. Near the inception of the recent IRS Voluntary Disclosure Program relating to previously undeclared foreign accounts, [i] the IRS examining … Continue reading Basic Audit Techniques: Taxpayer Interviews

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IRS Audit Techniques Guides

Historically, Internal Revenue Service 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 … Continue reading IRS Audit Techniques Guides

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