In its first decision of 2018, the US Tax Court considered whether the six-year statute of limitations in Code Section 6501(e)(1)(A)(ii) applied to a taxpayer who failed to file Foreign Bank Account Reporting, or FBAR forms from 2006 through 2008.
Happy New Year! With the close of the calendar year behind us, tax season is just beginning for individuals and many entities. If you are serving as the trustee of a complex trust, however, it’s not too late to take
Last week the Treasury Department’s Financial Crimes Enforcement Network (FinCEN) again extended the deadline for certain financial professionals to file foreign bank accounting reporting forms known as FBARs. In FinCEN Notice 2017-1, FinCEN announced a further extension of time for certain
The Internal Revenue Service advised tax professionals today that pre-paying 2018 state and local real property taxes in 2017 may be tax deductible under certain circumstances. The new tax law signed last week in Washington prohibited the deduction of prepaid
President Donald Trump signed the new 2018 tax law “Tax Cuts & Jobs Act” (TCJA) last week. The new TCJA law is a sweeping overhaul of the tax code. Generally, the provisions in the TCJA take effect on January 1,
Two years ago, Congress passed Internal Revenue Code Section 7345. This law allows the Internal Revenue Service (IRS) to work with the US State Department to suspend and/or deny the passports of taxpayers with seriously delinquent tax debts. The IRS plans
On November 3, 2017, the IRS announced an additional 11 compliance campaigns as areas of focus for the Large Business & International Division (“Announcement”). The 11 newly identified campaigns focus primarily on international issues, with seven international campaigns and four
An IRS CP 503 notice is a letter that the IRS sends out to individuals as a reminder and a means to collect on a tax debt balance. This letter is a final notice and follows previous attempts to receive