The U.S.A Continues to be AML/BSA “Vulnerable”
The U.S. Department of the Treasury 2020 Strategy (National Strategy for Combating Terrorist and Other Illicit Financing released on February 6, 2020) describes ongoing significant AML/BSA and CFT threats. The vulnerabilities in the U.S.A. related to AML/BSA and CFT are centered around: Lack of a requirement to collect entity beneficial ownership information Law enforcement efforts […]
What is Next after BSA turns 50?
On 2/6/2020, the U.S. Department of the Treasury issued the BSA 2020 National Strategy for Combating Terrorist and Other Illicit Financing (2020 Strategy). The purpose of the 2020 Strategy is to: • Modernize the U.S. anti-money laundering/countering the financing of terrorism (AML/CFT) regime and make it more effective and efficient. • Increase transparency and close […]
What can trigger an OFAC investigation and what can an OFAC Investigation lead to?
An OFAC investigation is often triggered as a result of: • Reports that are generated by U.S. Financial Institutions which have blocked or rejected a transaction based on a suspected sanctions violation • A self-disclosure of an OFAC apparent violation • Information OFAC receives from other U.S. agencies investigating other types of violations. • A […]
FBAR Penalties: Is it per Account or per Violation?
U.S. Taxpayers (includes a citizen, permanent resident, corporation, partnership, limited liability company, trust and estate) are required to file a Report of Foreign Bank and Financial Accounts (FBAR) if they have: a financial interest in or signature or other authority over at least one financial account located outside the United States, AND the aggregate value […]
Are there conflicting signals from IRS as it relates to Section 965?
IRC Section 965 (Treatment of Deferred Foreign Income Upon Transition to Participation Exemption System of Taxation) was part of the TCJA enacted on December 22, 2017. The sections requires a United States shareholder to pay a transition tax on the untaxed foreign earnings of certain specified foreign corporations as if those earnings had been repatriated […]
Payers and Payees have Obligations to Comply with Backup Withholding
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, OR • fails to report interest, dividend, or patronage dividend income. A payer must withhold […]
IRS “BEEFS UP” Section 965 COMPLIANCE for 2017 and 2018 Returns
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 tax” on the untaxed foreign earnings of certain specified foreign corporations as if those earnings […]
Indirect linkages to Tax Havens
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 their reportable worldwide income. According to the most current Federal Tax Compliance Research Report, there […]
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 […]
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 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 […]
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 Taxpayer’s tax home; as a travel expense deduction may attract the attention of the IRS. […]
