I recently read a very interesting report issued by the Treasury Inspector General for Tax Administration (TIGTA) on the topic of the IRS Examination function failing to consider the collectibility of potential assessments. Collectiblity is simply the likelihood the...
Taking A Cooperative Approach To Your Legal Issues
Firm News
Not Required to File a Tax Return? Maybe You Should File Anyway
The IRS offers five reasons why you should file a tax return even when it is not required. According to the IRS: Most people file a tax return because they have to. Even if a taxpayer doesn’t have to file, there are times they should. They may be eligible for a tax...
NRP Audits – The Honest Taxpayer’s Worst Nightmare
An audit by the IRS of tax returns can be very intimidating. When the IRS audits a taxpayer they usually don’t look at every single line item on a tax returns, and they don’t’ look at every single receipt. This is particularly true when a taxpayer demonstrates...
New FBAR Filing Due Date in Effect
Some U.S persons that have a financial interest in, or signature authority over, financial accounts outside the United States are required to file FinCEN Report 114, commonly referred to as the FBAR. This requirement is imposed by the Bank Secrecy Act. The law has...
U.S. v. Bohanec – Another Court Case on the Willful FBAR Penalty
U.S. v. Bohanec, a case decided in the U.S. District Court for the Central District of California, involved a married couple both of whom immigrated to the United States. They owned a camera shop that grew to a successful international business using Ebay as their sales platform. They started depositing income earned outside the United States in a bank account…
CHANGES IN IRS ENFORCEMENT PRIORITIES: FBARs and OFFSHORE VOLUNTARY DISCLOSURES (OVDP)
The IRS, in recent years, is enforcing rules requiring “U.S. Persons[1]”to register (by filing an FBAR or related form) almost all foreign financial accounts, whether residing in the U.S. or abroad. They are requiring registration of these accounts, even if the...
PANAMA PAPERS: A POSSIBLE TREASURE TROVE FOR THE IRS AND WORLD-WIDE TAX ENFORCEMENT: WHO NEEDS FATCA?
The impact of the Panama Papers mega-news story is being absorbed with lightning speed around the globe. The tax compliance community is going to feel the ripples for the next several years. The real story is not so much the disclosure of world leaders whose names...
Owe Taxes: Your Passport is at Risk
The U.S. Department of State is responsible for granting and renewing passports. In late 2015, President Obama signed into law a provision that will allow the State Department to decline issuance of a passport and revoke already issued passports when a federal tax debt is owed of $50,000 or more. New Internal Revenue Code section 7345 requires the IRS to…
IRS Collections – An Overview
The IRS has procedures in place that guide how the IRS goes about collecting a debt owed by a taxpayer. The IRS collects debt from taxpayers through both involuntary means, like levies on income and assets, and voluntary means like an installment agreement. As you can imagine, the sheer number of taxpayers and the amount of dollars that the IRS…
FATCA UPDATE: EASING THE “BURDEN” ON FOREIGN BANKS AND THE LIST OF “BAD” BANKS
FATCA has been on the books since 2010. While the United States is taking the heat for pushing for an Orwellian, virtual, international banking and taxation data base, recall that the overwhelming majority of developed countries are unabashedly “FATCA Friendly.” Just...