Is it time for Foreign Financial Institutions to hire IRS Representation?
Is it time for Foreign Financial Institutions to hire IRS Representation? published by JD Supra on 1/23/19. The Responsible Officer (RO) of a Participating Foreign Financial Institution (PFFI) or Reporting Model 2 FFI is required to file the FFI’s FATCA certification of an Entity’s preexisting accounts (COPA) and its Periodic Certification (PC) relating to an […]
Don’t Jeopardize Your Passport: The US State Department Is Held Harmless!
Don’t Jeopardize Your Passport: The US State Department Is Held Harmless! was published by the Daily Business review on 1/8/19.
Understanding how IRS identifies and selects Individual Tax Returns for Automated Underreporter Review
Understanding how IRS identifies and selects Individual Tax Returns for Automated Underreporter Review was published by JD Supra on 1/8/19. The IRS Automated Underreporter Matching Process matches Tax Returns against Information Returns. IRS states that there were approximately 150 million individual tax returns filed in 2017 and about 25 million of them (17%) had a “mismatch”; […]
IRS-Criminal Investigations: going on 100 years and still looking at Tax Crimes!
IRS-Criminal Investigations: going on 100 years and still looking at Tax Crimes! was published by JD Supra on 1/8/19. On November 11, 2018, the IRS released its Criminal Investigation Annual Report as it begins its 2019 fiscal year and its 100th anniversary as a law enforcement agency. IRS-Criminal Investigation (IRS-CI) is a federal agency department […]
What is Tax Evasion?
What is Tax Evasion? was published by JD Supra on 12/7/18. The IRS TAX CRIMES HANDBOOK states that there are two kinds of tax evasion: (a) the willful attempt to evade or defeat the ASSESSMENT of a tax, and (b) the willful attempt to evade or defeat the PAYMENT of a tax. Meaning, if a […]
What is Reasonable Cause for the IRS?
What is Reasonable Cause for the IRS? was published by JD Supra on 12/7/18. In the US, Taxpayers “self-assess and voluntarily” pay taxes. The IRS position is that Voluntary Compliance occurs when a Taxpayer makes a “good faith” effort to meet the Taxpayer’s tax obligations as defined in the Internal Revenue Code. IRS encourages Taxpayer Voluntary […]
Do you own a Rental income is reportableor a vacation home that you rent out?
Do you own a second home or a vacation home that you rent out? was published by JD Supra on 11/30/18. Rental income is reportable on a Taxpayer’s tax return. Certain expenses such as mortgage interest, real estate taxes, casualty losses, maintenance, utilities, insurance, and depreciation may be deducted from a Taxpayer’s rental income from the […]
IRS Guidance on Business Meals is Transitional
IRS Guidance on Business Meals is Transitional was published by JD Supra on 11/30/18. The Tax Cut and Jobs Act (TCJA) amended Section 274 of the Internal Revenue Code (IRC) created a confusion for Taxpayers by disallowing a deduction for expenses with respect to “entertainment”, amusement, or recreation and failing to address the deductibility of expenses […]
Understanding Estate and Gift Taxes
Understanding Estate and Gift Taxes was published by JD Supra on 11/21/18. Although only .2% of US Taxpayers actually pay Estate Taxes (Congress’s Joint Committee on Taxation), it is important to understand how Estate Tax works in conjunction with gifting. Taxpayers work hard to create wealth. Its transfer is an important concept. What is the Federal […]
Tax Fraud and the Element of Willfulness
Tax Fraud and the Element of Willfulness was published by JD Supra on 10/23/18. Tax fraud is often defined as an intentional wrongdoing on the part of a Taxpayer with the specific purpose of evading a tax known or believed owed. Tax fraud requires: A tax due and owing resulting from a deliberate intent to […]
Don’t forget about your Right to Retain Representation
Don’t forget about your Right to Retain Representation was published by JD Supra on 10/23/18. Taxpayers have a Taxpayers Bill of Rights: ten fundamental rights available to them when dealing with the IRS. They are: The Right to Be Informed The Right to Quality Service The Right to Pay No More than the Correct […]
Understating Form W-7 and the ITIN
Understating Form W-7 and the ITIN was published by JD Supra on 10/18/18. An Individual Taxpayer Identification Number (ITIN) is a tax processing number issued by the IRS to foreign nationals and others who have federal tax reporting or filing requirements and do not qualify for Social Security Numbers (SSNs). ITINs are issued regardless of immigration […]
