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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 […] Read More…

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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 […] Read More…

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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 […] Read More…

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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 […] Read More…

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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 […] Read More…

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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, […] Read More…

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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 […] Read More…

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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 […] Read More…

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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 […] Read More…

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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. […] Read More…

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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 […] Read More…

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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 […] Read More…

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