Search Results for: audit
Resolving IRS disputes through audit reconsideration
…of “rework” of a previous audit where some issues remain unresolved. In a typical audit reconsideration situation, the taxpayer believes that the audit resulted in an inappropriate increase in tax…
New Jersey Department of Revenue publishes “Manual of Audit Procedures”
…demonstrated that all returns were filed correctly. This discontinued the audit before it even started. 8.11 Walk-Away Audit If, after the pre-audit interview with the taxpayer, the auditor determines that…
15 IRS Audit Tips
…reconstruct records. 11. Do not bring to an audit any documents that do not pertain to the year under audit or were not specifically requested by the audit notice. 12….
Audit Beware: IRS’ Global High Wealth Industry Group
…for an audit. Those that are targeted can expect a particularly rigorous audit. The new unit combines seasoned revenue agents (auditors) with offshore examiners and specialists capable of auditing every…
Beware Expected Employee Retention Credit (ERC) Audits
…IRS ERC audit process is complex and can be daunting for businesses that are not familiar with it. The IRS will first send you a notice of audit, which will…
Post IRS Audit Strategic Options: The IRS’ 30 Day Letter
…types of tax controversy matters, including IRS appeals and audits. If you are facing an audit or determining whether to appeal an audit, please contact us for a free consultation….
U.S. Taxpayers at New Risk of Audit from OVDP Declines and Withdrawals Campaign
…taxpayer receives a soft letter, the IRS will list a number of options to resolve the taxpayer’s non-compliance, requiring a response from the taxpayer. Examination (audit) by the IRS for…
30-DAY LETTERS VS. 90-DAY LETTERS IN TAX AUDITS
In a tax audit situations, the IRS only has a 3 year statute of limitations to assess additional taxes. If the IRS takes too long to initiate an audit, or…
IRS Audits of Millionaires Remain Very Low
…information, which indicate that only one mandatory audit of his returns was initiated during his administration but wasn’t finished. Steady Drop in Audits Over the Years Overall, budget cutbacks over…
The IRS’ Complex Statute of Limitations
An IRS tax audit can be expensive and stressful. That is why is always important to check whether the IRS statute of limitations has expired for the audit. The expiration…
ABA COMMENTS ON THE 2014 OFFSHORE VOLUNTARY DISCLOSURE PROGRAM AND THE STREAMLINED PROGRAMS
…the context of partnership audits, where the IRS has recognized that the costs of applying partnership-level adjustments to numerous partners can outweigh the tax at issue and has, through Form…
New IRS Disclosure Program Announced for Non-Resident Taxpayers: Streamlined Foreign Offshore Procedures
…analyzed. While taxpayers in the SFOP are not automatically audited, an SFOP filing is subject the possibility of normal audit selection. Under such audit, the taxpayer should be prepared to…
Employee or Contractor?: The IRS’s New Voluntary Classification Settlement Program (VCSP)
…three years; Not currently be under audit by the IRS; Not currently be under audit by the Department of Labor or a state government agency concerning worker classification; and If…
New IRS IRM with Updated Streamlined Filing Compliance procedures
The Internal Revenue Manual (IRM) is essentially the IRS employee handbook on how to carry out all administrative and procedural matters, such as how to audit specific tax returns, collect…
New Court Case Limits the Reasonable cause exception to FBAR penalties
…In 2011, the IRS conducted an audit into the Jarnagins’ tax returns for 2008 and 2009. The audit revealed two wire transfers from the CIBC account. While the tax amounts…
The “Quiet” or “Silent” Disclosure
…hopefully avoid further IRS scrutiny (i.e., an audit whereby the IRS decides whether to impose the statutory penalties). By making a “quiet” disclosure, a taxpayer runs the risk of being…
New Streamlined Domestic Offshore Procedures (SDOP) is a Game Changer
…analyzed. While taxpayers in the SDOP are not automatically audited, an SDOP filing is subject the possibility of normal audit selection. Under such audit, the taxpayer should be prepared to…
What I learned at the 2022 National Institute on Criminal Tax Fraud and Tax Controversy in Las Vegas
…levels and positions, including auditors, criminal investigation agents, collection agents, etc. Senior officials from the IRS solicited attendees, including many seasoned tax attorneys, to consider applying for jobs at the…
Full Analysis of Updated 2012 OVDP Program
…handled under the traditional IRS audit process. A taxpayer may choose to opt out when the result reached under the 2012 OVDP penalty framework (see next section) appears too severe…
OVDP Ineligibility Possibility Increases
…taxpayer was contacted by the government (or otherwise investigated or under criminal/civil audit) they were no longer eligible for OVDP. For example, HSBC India, which provided numerous U.S. accountholders names,…
What Do Tax Lawyers Do?
…of the tax code. Tax lawyers typically have expertise in at least one of the following issues: Audit Representation: If you receive a straightforward audit notice from the IRS, you…
Penalty relief for International Information Forms 5471, 5472, and 8865
…may be selected for audit through the existing audit selection processes that are in place for any tax or information returns.” Note that the use of “information returns filed with…
IRS Revises Delinquent International Information Return Submission Procedure (DIIRSP)
…with amended returns will not be automatically subject to audit but may be selected for audit through the existing audit selection processes that are in place for any tax or…
IRS examines jewelry, precious stones and metals businesses for compliance
…Form 8300 compliance. This audit is very much like a tax audit; the IRS checks records to look for receipt of cash payments that required filing of the 8300 form….
NJ Division of Taxation Offers Offshore Voluntary Compliance Initiative
…Tax Audit Branch PO Box 288 Trenton, New Jersey 08695-0288 For questions concerning individuals and partnerships: please call the Individual Tax Audit Branch at 609-292-2163 and ask for Supervisor Dan…
Opt Out of OVDI Program Penalties to Get a Lower Penalty
…opt out there is still hope because an appeal is available to contest an OVDI opt-out penalty. Opt outs are essentially audits, and audit determinations can be appealed in the…
Appeals of penalties imposed during the Offshore Voluntary Opt-Out
…there any appeal available to contest an OVDI opt-out penalty? Yes. Opt outs are essentially audits, and audit determinations can be appealed in the same manner as lesser court rulings,…
Beware IRS Letter 6291
…targeted taxpayers identifying tax noncompliance and passively seeking compliance. Failure to respond to such letters may result in audit or penalties and possible criminal prosecution. However, prior to audit, taxpayers…
IRS announces two new intriguing targeted enforcement campaigns
…campaigns, the failure to respond to such letters may result in audit or penalties and possible criminal prosecution. As a result, we expect increased IRS audit activity for clients with…
The Dreaded IRS Letter 6185: “We received information that you have a foreign account”
…Failure to respond to such letters may result in audit or penalties and possible criminal prosecution. However, prior to audit, taxpayers can still become compliant by entering one of the…