Taxpayers, have you sold, received, exchanged or acquired Virtual Currency?
During the month of October 2019, IRS issued Revenue Ruling 2019-24, FAQ’s on Virtual Currency Transactions and a DRAFT Form of Schedule 1, which, for the first time presents the question: “At any time during 2019, did you receive, sell, send, exchange, or otherwise acquire any financial interest in any virtual currency”? The Compliance Checkbox […]
An IRS “John Doe” Summons is a Powerful Weapon that can Puncture Attorney-Client Privilege
An individual that provides information to an attorney may normally assume that the information provided to the attorney will be kept confidential under the attorney-client privilege. That said, according to the Internal Revenue Manual (IRM), circumstances exist when attorney client privilege protection may be circumvented by an IRS weapon known as a “John Doe” summons. […]
The OFAC Sanctions Compliance Program applies to all
OFAC (Office of Foreign Assets Control) is a department of the US Treasury that administers and enforces economic and trade sanctions based on US foreign policy and national security goals. On May 2, 2019, OFAC published guidance titled “A Framework for OFAC Compliance Commitments”. The purpose of the OFAC Framework guidance is to encourage […]
Why is it important to choose the right Power of Attorney for your IRS representation?
Circular 230 (Regulations Governing Practice before the Internal Revenue Service) governs those that are authorized to practice in front of the IRS: Attorneys, CPAs and Enrolled Agents. Practicing in front of the IRS means that those authorized may: Communicate with the IRS on behalf of a Taxpayer regarding the Taxpayer’s rights, privileges, or liabilities under […]
Did you know that there is FCPA Individual Compliance Responsibility?
The Foreign Corrupt Practices Act (FCPA) prohibits payment of bribes to foreign officials to assist with obtaining or retaining business. It also requires companies whose securities are listed in the US to make and keep books and records that accurately and fairly reflect their transactions as well as to devise and maintain an adequate system […]
Did you know that the IRS has 59 Compliance Campaigns? Have your Audit Plan Ready!
IRS Large Business and International (IRS LBI) currently has 59 Active Compliance Campaigns. The purpose of the IRS compliance campaign strategy is to redefine large business compliance work and build a supportive infrastructure inside the LBI. The campaigns require strategic planning and deployment of IRS knowledge resources in order to address non-compliance issues. The campaigns […]
Automatic Exchange of Information leads to Deposit Drops at International Financial Centers
On June 7, 2019, the Organisation for Economic Co-operation and Development (OECD) released a Memo which is a “summary of ongoing work to assess the impact of increasing tax transparency and exchange of information (EOI) on cross-border financial activity using international investment data”. The publication’s headline conclusion is that deposits in International Financial Centres (IFCs) […]
Guilty from the Get-go in the IRS Updated Voluntary Disclosure Program?
On June 20, 2019, the National Taxpayer Advocate (TA), an independent organization within the IRS that helps taxpayers and protects taxpayer rights, issued a final Report to Congress. A section of the report focused on the TA’s request for the assistance of Congress with obtaining clarity and certainty regarding certain aspects of the IRS Updated […]
Could your Organization be holding Virtual Currency that is “blockable” pursuant to OFAC’s regulations?
OFAC (Office of Foreign Asset Control) compliance applies to all US persons; including, all US citizens and permanent resident aliens regardless of their location, all persons and entities within the US, all US incorporated entities and their foreign branches, all organizations subject to US jurisdiction, foreign entities that conduct business in or with the US […]
IRS Initiates a Compliance Campaign for U.S. Persons with respect to Certain Foreign Corporations (Form 5471)
IRS Form 5471 is used by certain U.S. persons who are officers, directors, or shareholders in certain foreign corporations and must be attached to a covered Taxpayer’s Tax Return. On April 16, 2019, IRS announced the approval of three additional Compliance Campaigns bringing the total of IRS Compliance Campaigns to fifty three (53). IRS Compliance […]
IRS using Data Analytics to Uncover Criminal Arrangements
IRS using Data Analytics to Uncover Criminal Arrangements article appeared on JD Supra on 8/20/19. IRS-Criminal Investigation (IRS-CI) is a federal agency department specifically authorized to investigate and prosecute federal income tax crimes. IRS-CI uses data analytics such as models, algorithms, and the millions of records and evidence that IRS-CI has at hand to help […]
When do you need an IRS Certifying Acceptance Agent?
When do you need an IRS Certifying Acceptance Agent? Article appeared at JD Supra on 8/15/19. There are foreign national Individuals and other foreign Persons that do not have or do not qualify for a Social Security Number (SSN) but need a Taxpayer Identification Number (TIN) to file certain tax forms and schedules including IRS […]
