Category Archives: COMPLIANCE

OWE TAXES? NO PASSPORT! IRS MAY SCUTTLE TRAVEL PLANS OF THOSE WHO DON’T PAY UP

Posted on November 24, 2015 by taxpenaltylawyer

Congress has a sneaky habit of attaching tax bills to end-of-the-year highway funding legislation. HR22, the Surface Transportation Reauthorization and Reform Act of 2015,” has tucked into Title 52 a nasty little tax ditty that creates new Internal Revenue Code … Continue reading →

Posted in COMPLIANCE, PASSPORTS AND TAX DEBTS, STREAMLINED FILING COMPLIANCE PROCEDURES, Uncategorized | Tagged , , , , | Leave a comment

SOME CLARIFICATION FROM IRS ON THE STREAMLINED FILING COMPLIANCE PROCEDURES.AND DEINQUENT INTERNATIONAL INFORMATION RETURN SUBMISSIONS.

Posted on November 9, 2014 by taxpenaltylawyer

The IRS has updated its Streamlined Filing Compliance Procedures and Delinquent International Information Return pages (October 9, 2014) and issued Frequently Asked Questions with regard to each. The FAQs for U.S. Taxpayers residing in the U.S. clarify that: The 5% … Continue reading →

Posted in 214 OVDP, COMPLIANCE, FBARS, OFFSHORE BANK ACCOUNTS, TAX | Tagged , , , , , , , , | 1 Comment

INITIAL THOUGHTS ON IRS CHANGES TO OFFSHORE VOLUNTARY DISCLOSURE PROGRAM AND STREAMLINED PROCESS FOR NON-WILLFUL TAXPAYERS

Posted on June 19, 2014 by taxpenaltylawyer

Yesterday, June 18, 2014, IRS announced and posted to the Offshore Voluntary Disclosure page on its website (www.irs.gov) significant changes to the 2012 OVDP reflected in revised Frequently Asked Questions; and, new Streamlined Filing Compliance Procedures for non-willful, out-of-compliance taxpayers, whether … Continue reading →

Posted in 2012 OVDP, COMPLIANCE, FBARS, NEW OVDP, TAX, VOLUNTARY DISCLOSURE | Tagged , , , , , , , , , , , , | 11 Comments

MORE ON GOVERNMENT SHUT DOWN IMPACT ON TAX FILINGS AND OVDP SUBMISSIONS

Posted on October 8, 2013 by taxpenaltylawyer

The IRS has updated in webpage with information, “IRS Operations During the Lapse in Appropriations.” http://www.irs.gov/uac/Newsroom/IRS-Operations-During-The-Lapse-In-appropriations Some additional guidance: E-filed returns will be processed normally although refunds will not be issued. Paper returns can be filed but will not be … Continue reading →

Posted in 2012 OVDP, COMPLIANCE, RETURNS, TAX | Tagged , , , , , , | Leave a comment

UPDATE ON IMPACT OF GOVERNMENT SHUT-DOWN ON IRS AND TAX COURT OPERATIONS

Posted on October 4, 2013 by taxpenaltylawyer

As reported by the Journal of Accountancy as of October 1, 2013: IRS OPERATIONS ONGOING Processing tax returns submitted with payments. Processing all e-filed returns. Filing deadlines remain as required by law.  Thus, individual returns must be filed by 10/15/13 … Continue reading →

Posted in AUDITS, COMPLIANCE, EMPLOYMENT TAXES, RETURNS, TAX | Tagged , , , , | Leave a comment

IMPACT OF GOVERNMENT SHUT-DOWN ON IRS

Posted on October 2, 2013 by taxpenaltylawyer

The IRS has announced what is operational and not during the government shut-down.  Below is the text of the IRS announcement.  IRS Operations During The Lapse In Appropriations Due to the current lapse in appropriations, IRS operations are limited. However, the underlying … Continue reading →

Posted in AUDITS, COMPLIANCE, FBARS, IRS COLLECTIONS, RETURNS, TAX | Tagged , , , , | Leave a comment

MORE ON RETURNS OF SAME-SEX COUPLES

Posted on September 11, 2013 by taxpenaltylawyer

It is noteworthy that the IRS announced new rules for same-sex couples  (Rev. Rul. 2013-17) discussed in my post of 9/3/2013 (IRS Issues Rules for Same-Sex Couples) applies to original or amended tax returns filed on or after September 16, 2013.  This means … Continue reading →

Posted in AMENDED RETURNS, COMPLIANCE, DELINQUENT RETURN, JOINT RETURNS, RETURNS, TAX | Tagged , , , , , , | Leave a comment

NOOSE TIGHTENING ON UNREPORTED OFFSHORE ACCOUNT HOLDERS

Posted on August 17, 2013 by taxpenaltylawyer

August has been a busy month for weaving tighter the growing web of international snares laid for catching offshore tax evaders. On August 13, the U.S. and Cayman Islands announced agreement on a Model 1 Intergovernmental FATCA implementation agreement.  Under … Continue reading →

Posted in 2012 OVDP, COMPLIANCE, FBARS, NEW OVDP, TAX, TAX INFORMATION EXCHANGE AGREEMENTS, VOLUNTARY DISCLOSURE | Tagged , , , , , , , , , , , | 2 Comments

E-FILING OF FBARS NOW MANDATORY

Posted on August 5, 2013 by taxpenaltylawyer

The Financial Crimes Enforcement Network (FinCEN) has issued its Final Notice requiring the electronic filing of most Bank Secrecy Act (BSA) reports by July 1, 2012. The mandated reports filed by financial institutions include: Suspicious Activity Reports (SARs) filed by … Continue reading →

Posted in 2012 OVDP, COMPLIANCE, FBARS, TAX, TAX CRIMES | Tagged , , , , , | Leave a comment

WHAT CONDUCT WILL TRIGGER THE 75% CIVIL FRAUD PENALTY OF IRC SECTION 6663?

Posted on June 4, 2013 by taxpenaltylawyer

 In Ward v. Commissioner, T.C. Memo. 2013-133 (May 29, 2013), Mr. Ward sought redetermination of an IRS proposed deficiency on a number of grounds. This post addresses only his disputation of the civil fraud penalty proposed.  Judge Kerrigan’s decision contains … Continue reading →

Posted in COMPLIANCE, DELINQUENT RETURN, TAX | Tagged , , , , , | Leave a comment