Payers and Payees have Obligations to Comply with Backup Withholding

December 2019

Backup Withholding requires a payer to “withhold tax” from payments that are not otherwise subject to withholding.  A Taxpayer (payee) may be subject to Backup Withholding if it: • fails to provide a correct taxpayer identification number (TIN) when required,

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IRS “BEEFS UP” Section 965 COMPLIANCE for 2017 and 2018 Returns

November 2019

On July 2, 2018, the IRS introduced a Compliance Campaign directed at Section 965 (Transition Tax) of the Internal Revenue Code (IRC).  In its original launch, the Section 965 Campaign stated that U.S. shareholder are required to pay a “transition

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Indirect linkages to Tax Havens

November 2019

The U.S. income tax system is based on the idea of voluntary taxpayer compliance. It is the taxpayer’s responsibility to report all reportable worldwide income. Some people attempt to evade paying taxes by failing to report all or some of

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Taxpayers, have you sold, received, exchanged or acquired Virtual Currency?

November 2019

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,

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Why is it important to choose the right Power of Attorney for your IRS representation?

October 2019

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

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Did you know that the IRS has 59 Compliance Campaigns? Have your Audit Plan Ready!

October 2019

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

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Your Tax Home and Travel Expense Deductions

August 2019

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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IRS using Data Analytics to Uncover Criminal Arrangements

August 2019

IRS-Criminal Investigation (IRS-CI) is a federal agency department specifically authorized to investigate and  https://www.jdsupra.com/legalnews/irs-using-data-analytics-to-uncover-67780/

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When do you need an IRS Certifying Acceptance Agent?

August 2019

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  https://www.jdsupra.com/legalnews/when-do-you-need-an-irs-certifying-16624/

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Does it make sense to go from an S-Corp to a C-Corp?

August 2019

IRS defines an S-Corp as a corporation whose shareholders make the election to pass corporate income, losses, deductions, and credits through to their shareholders for https://www.jdsupra.com/legalnews/does-it-make-sense-to-go-from-an-s-corp-45960/

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What is an Abusive Tax Trust?

August 2019

In a “legitimate” Trust, the ownership and control of the Trust assets and income is “separate” from a Settlor’s control and https://www.jdsupra.com/legalnews/what-is-an-abusive-tax-trust-56770/

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Understanding how Taxpayers may Appeal to the IRS Office of Appeals

July 2019

IRS has an Office of Appeals (OOA) that operates as an “independent” organization within the IRS. The goal of the OOA is to  https://www.jdsupra.com/legalnews/understanding-how-taxpayers-may-appeal-93524/

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