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 […]
An IRS “John Doe” Summons is a Powerful Weapon that can Puncture Attorney-Client Privilege
An individual that provides information to an attorney may normally assume that the information provided to the attorney will be kept confidential under the attorney-client privilege. That said, according to the Internal Revenue Manual (IRM), circumstances exist when attorney client privilege protection may be circumvented by an IRS weapon known as a “John Doe” summons. […]
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 […]
Automatic Exchange of Information leads to Deposit Drops at International Financial Centers
On June 7, 2019, the Organisation for Economic Co-operation and Development (OECD) released a Memo which is a “summary of ongoing work to assess the impact of increasing tax transparency and exchange of information (EOI) on cross-border financial activity using international investment data”. The publication’s headline conclusion is that deposits in International Financial Centres (IFCs) […]
Guilty from the Get-go in the IRS Updated Voluntary Disclosure Program?
On June 20, 2019, the National Taxpayer Advocate (TA), an independent organization within the IRS that helps taxpayers and protects taxpayer rights, issued a final Report to Congress. A section of the report focused on the TA’s request for the assistance of Congress with obtaining clarity and certainty regarding certain aspects of the IRS Updated […]
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 Compliance Campaigns bringing the total of IRS Compliance Campaigns to fifty three (53). IRS Compliance […]
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 U.S. Corporation or a Foreign Corporation Engaged in a U.S. Trade or Business. The purpose […]
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 of being identified by the IRS and having IRS determine the Taxpayer’s taxable income (taxpayer […]
Is your Passport at Risk?
Is your Passport at Risk? was published by JD Supra on 5/21/19. Certain US Taxpayers that have been identified by IRS with overdue tax bills maybe at risk of losing US passport privileges. IRS has been trying to encourage US Taxpayers that are seriously behind on their taxes to pay what they owe or enter […]
IRS: Offshore Financial Accounts will NOT go Unnoticed
IRS: Offshore Financial Accounts will NOT go Unnoticed was published by JD Supra on 5/14/19. On March 15, 2019, IRS reported that hiding money or assets in unreported offshore accounts remains on the Internal Revenue Service’s “Dirty Dozen” list of tax scams for 2019. IRS continues to remind US Taxpayers to report their worldwide income […]
El Nudo Corredizo se está Cerrando
El Nudo Corredizo se está Cerrando was published by JD Supra on 5/1/19. Ahora que el IRS lleva cuatro años intercambiando datos de FATCA en sus computadoras y se está embarcando en una Campaña de Exactitud de Presentación de FATCA, existe una urgencia especial para los Contribuyentes Estadounidenses fuera de cumplimiento que no existía anteriormente. […]
The Noose is Closing
The Noose is Closing was published by JD Supra on 5/1/19. Now that IRS has four years of FATCA exchanged data in its computers and is embarking on a FATCA Filing Accuracy Campaign, there is a special urgency for for noncompliant U.S. Taxpayers that did not previously exist. Since March 2010, the U.S. has crafted […]
