Did you know that the IRS is Involved with Investigating and Prosecuting Bribery?
In 1977, the United States enacted the Foreign Corrupt Practices Act (FCPA). The FCPA prohibits an offer, payment, promise or the authorization of a payment of money or anything of value (a/k/a bribery) to a foreign official for the purpose
- Foodman website and JD Supra
¿Sabías que la OFAC y el IRS tienen un Entendimiento?
En Noviembre del 2019, el IRS y la Oficina de Control de Activos Extranjeros (“OFAC”) firmaron un Memorando de Entendimiento (“MOU”). El MOU describe un entendimiento entre el IRS y la OFAC con respecto a las revisiones realizadas por el
- Foodman website and JD Supra
An Interagency Statement from Regulators and a FinCEN Statement provide clarity Regarding Enforcement Actions
On August 13, 2020, the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, the National Credit Union Administration and the Office of the Comptroller of the Currency issued a JOINT STATEMENT ON ENFORCEMENT OF BANK
- Foodman website and JD Supra
Violating the FCPA may Trigger other U.S. Laws such as the Travel Act
There are other U.S laws that intersect with the FCPA. A violation of the FCPA may also constitute a violation of the characteristics of another U.S. Law – in this case the Travel Act. If the conduct of an Entity
- Foodman website and JD Supra
U.S. Financial Institutions and FATCA
Little is written regarding FATCA and U.S. Financial Institutions (FI). That said, U.S. FIs have FATCA responsibilities. In the absence of permitted exceptions, FATCA requires U.S. FIs that make payments of most types of U.S. source withholdable income to non-U.S.
- Foodman website and JD Supra
How does IRS Identify Cases with Audit Potential?
Understanding how the IRS identifies cases that have audit potential can be learned from the CONGRESS OF THE UNITED STATES (CONGRESSIONAL BUDGET OFFICE) Report released on July, 2020: Trends in the Internal Revenue Service’s Funding and Enforcement. This report addresses
- Foodman website and JD Supra
What happens when Taxpayers try to tell the IRS that it is not “Mea Culpa”?
According to the IRS Manual, reasonable cause for abating penalties is based on all the facts and circumstances of a Taxpayer’s situation. IRS will consider reasons which establish that a Taxpayer used all ordinary care and prudence to meet required
- Foodman website and JD Supra
Audit Time for High Income Individuals and their Companies has arrived
On a webinar hosted by the New York University Tax Controversy Forum on June 18, 2020, Douglas O’Donnell (head of the IRS Large Business and International Division/IRS-LBI) stated that the IRS will begin a new campaign to audit hundreds of
- Foodman website and JD Supra
Willfulness and IRS Foreign Account Reporting Requirements
The IRS Mission Statement states that: “the taxpayer’s role is to understand and meet his or her tax obligations”. Taxpayers fill out their own returns under a “self-assessment voluntary reporting system” because the Taxpayer is the one that possess all
- Foodman website and JD Supra
Did you know that IRS reinstated the “ASFR” program in 2019?
Under Internal Revenue Code, Section 6620, if a Taxpayer does not timely file a U.S. tax return, the IRS is authorized to prepare and file a U.S. tax return for that Taxpayer based on the knowledge that it has on
- Foodman website and JD Supra
How does the “Accounting” for a Forgivable Loan received under the PPP work?
The PPP (Paycheck Protection Program) was established by Congress to assist small businesses during the Covid-19 pandemic as part of the $2 trillion CARES Act. Via the PPP, the U.S. Treasury requires the U.S. Small Business Administration (SBA) to fund
- Foodman website and JD Supra
IRS has a Commitment to Service US Taxpayers and Enforce Collections Compliance
According to the Internal Revenue Code, Taxpayers have three obligations: (1) to file timely returns; (2) to file accurate returns; and (3) to pay the required tax voluntarily and timely. Voluntary compliance, in which Taxpayers determine the correct amount of
- Foodman website and JD Supra
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