Tag Archives: # INDIVISIBLE

DEPENDENCY EXEMPTION DENIED WHEN FORM 8332 RECEIVED WHEN IRS COULD NO LONGER ASSESS TAX AGAINST FORMER SPOUSE WHO HAD ALSO CLAIMED THE EXEMPTION

Tax Court Summary Decisions are not precedent but can be educational.  In David Charles Katz and Mary Joan Wring v. Commissioner, T.C. Summary Opinion 2013-98, the Tax Court again upheld the IRS denial of a dependency exemption when Form 8332 … Continue reading

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LATEST DOJ ATTACK ON OFFSHORE ACCOUNTS: JOHN DOE SUMMONSES ISSUED TO U.S. CORRESPONDENT BANKS OF OFFSHORE BANKS

By now, I’m sure anyone owning an undisclosed offshore bank account has become familiar with the term, “John Doe Summons.”  After all, following the IRS issuing a John Doe Summons to UBS, it announced the 2009 OVDP, and about 15,000 … Continue reading

Posted in 2012 OVDP, FBARS, NEW OVDP, OFFSHORE BANK ACCOUNTS, TAX, VOLUNTARY DISCLOSURE | Tagged , , , , , , , , , , , , , , , , , | Leave a comment

ACCIDENTAL U.S. TAX RESIDENTS CAUGHT IN OFFSHORE DISCLOSURE WEB

One of the difficult aspects of U.S. tax law for foreign persons to understand is how they become accidental U.S. tax residents.  Even those here without a Green Card on non-immigration visas, can be required in any given year to … Continue reading

Posted in 2012 OVDP, AMENDED RETURNS, NEW OVDP, OFFSHORE BANK ACCOUNTS, TAX, VOLUNTARY DISCLOSURE | Tagged , , , , , , , , , , | Leave a comment

CAUTION: IRS MAY ALREADY HAVE YOUR NAME OR WILL SOON. OFFSHORE DRAGNET LEADS UNNAMED FOREIGN BANKS TO COOPERATE

Some still out in the cold with offshore financial accounts take comfort in the fact that their bank has not yet been indicted or named in any publicly announced IRS investigation.  Well, here is some sobering news to shake confidence … Continue reading

Posted in 2012 OVDP, OFFSHORE BANK ACCOUNTS, TAX, TAX CRIMES, VOLUNTARY DISCLOSURE | Tagged , , , , , , , , , , , , , , | Leave a comment

MORE STORM CLOUDS FOR HIDDEN OFFSHORE ACCOUNTS

The holes in which to hide for offshore tax cheats are steadily being filled up.  Those who have not entered the IRS Offshore Voluntary Disclosure Program, will find no comfort in some recent news, namely: Bank Frey, the “Truly Swiss, … Continue reading

Posted in 2012 OVDP, OFFSHORE BANK ACCOUNTS, TAX, TAX CRIMES | Tagged , , , , , , , , , , , | Leave a comment

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

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

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

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