Foodman CPAs and Advisors

Is it time for Foreign Financial Institutions to hire IRS Representation?

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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 […]

Due Diligence is necessary for Taxpayers to have the Right TAX Representative

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Due Diligence is necessary for Taxpayers to have the Right TAX Representative was published by JD Supra on 1/8/19. As 2018 comes to an end, many Taxpayers are wondering about their tax reporting situation under the Tax Cut Jobs Act.  Taxpayers ought to be asking themselves if their Tax Representative understands:  Although you itemized deductions […]

Winning Business Through Bribery Could Get You Into Trouble!

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Winning Business Through Bribery Could Get You Into Trouble! was published by JD Supra on 1/8/19. 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 of […]

IRS-Criminal Investigations: going on 100 years and still looking at Tax Crimes!

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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 […]

Should Business Owners rely on Whistleblowers or Forensic Accountants?

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Should Business Owners rely on Whistleblowers or Forensic Accountants? was published by JD Supra on 12/21/18. According to a recent Foreign Corrupt Practices Act (FCPA) Blog entry (11/28/18), over 40% of internal frauds are discovered by whistleblowers and statistics show that 74% of whistleblowers are terminated.   The National Center for Whistleblowers states that: “Whistleblowers are […]

Offshore Accounts Today Equal Transparency

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Offshore Accounts Today Equal Transparency was published by JD Supra on 12/18/18. The days of avoiding taxes through hiding money or assets in unreported offshore accounts are gone.  Nonetheless, there are still taxpayers with undeclared offshore accounts, as well as the banks and bankers that are suspected of helping clients hide their reportable assets overseas.   […]

IRS can start asking questions about Campaign Issues. Have your Audit Plan Ready!

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IRS can start asking questions about Campaign Issues. Have your Audit Plan Ready! was published by JD Supra on 12/14/18. On January 31, 2017, the IRS Large Business and International Division (LBI) announced a compliance campaign strategy to redefine large business compliance work and build a supportive infrastructure inside the LBI.  The campaigns require strategic planning […]

What is Tax Evasion?

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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 […]

How to determine an Individual’s Residency for Tax Treaty Purposes?

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How to determine an Individual’s Residency for Tax Treaty Purposes? was published by JD Supra on 12/7/18. The guidelines for determining an Individual’s tax residency are as follows:  An Individual Taxpayer is a resident based on the laws of one treaty-partner country and is considered to be a resident of that country for treaty purposes. […]