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
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Your Tax Home and Travel Expense Deductions
The Internal Revenue Code (IRC) permits a U.S. Taxpayer to deduct “certain travel expenses” when traveling away from home on business. Taxpayers ought to keep close attention to a travel expense deduction and ensure that it accurately correlates with a
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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
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Does it make sense to go from an S-Corp to a C-Corp?
Does it make sense to go from an S-Corp to a C-Corp? Article appeared at JD Supra on 8/9/19. IRS defines an S-Corp as a corporation whose shareholders make the election to pass corporate income, losses, deductions, and credits through
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What is an Abusive Tax Trust?
What is an Abusive Tax Trust? Article appeared at JD Supra on 8/9/19. In a “legitimate” Trust, the ownership and control of the Trust assets and income is “separate” from a Settlor’s control and benefit. IRS has been reporting that
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An effective compliance program can help diminish an organizational criminal fine
An effective compliance program can help diminish an organizational criminal fine. Article appeared at JD Supra on 7/30/19. On April 30, 2018, the Criminal Division of the US Department of Justice (DOJ) released a guidance document regarding corporate compliance programs. The
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If you Exchange Virtual Currency, you are a Money Transmitter and must comply with the Bank Secrecy Act (BSA)
If you Exchange Virtual Currency, you are a Money Transmitter and must comply with the Bank Secrecy Act (BSA) article was published by JD Supra on 7/23/19. FinCEN defines a Money Service Business (MSB) as any person DOING BUSINESS, whether
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Understanding how Taxpayers may Appeal to the IRS Office of Appeals
Understanding how Taxpayers may Appeal to the IRS Office of Appeals was published by JD Supra on 7/16/19. IRS has an Office of Appeals (OOA) that operates as an “independent” organization within the IRS. The goal of the OOA is
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Penalty of $25,000 for Foreigners with a 25% ownership stake or control of a U.S. legal entity that fail to file Form 5472
Penalty of $25,000 for Foreigners with a 25% ownership stake or control of a U.S. legal entity that fail to file Form 5472 was published by JD Supra on 7/9/19. Form 5472 is an Information Return of a 25% Foreign-Owned
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Is There an Anti-Money Laundering (AML) Component to the Revision of the IRS EIN Process?
Is There an Anti-Money Laundering (AML) Component to the Revision of the IRS EIN Process? was published by JD Supra on 6/25/19. An EIN is also known as a Federal Entity Tax Identification Number (EIN) and is used to identify
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IRS can Prove that a Taxpayer Under-Reported Income
IRS can Prove that a Taxpayer Under-Reported Income was published by JD Supra on 6/18/19. There are Taxpayers that understate income, overstate expenses and present fraudulent claims on their tax returns for credits and deductions. These Taxpayers run the risk
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Taxpayers can be Embarrassed when IRS Contacts a Third-Party
Taxpayers can be Embarrassed when IRS Contacts a Third-Party was published by JD Supra on 6/18/19. Under Internal Revenue Code (IRC), Subtitle F – Income Taxes, Chapter 78 – Discovery of Liability and Enforcement of Title, Subchapter A – Examination
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