ABA COMMENTS ON THE 2014 OFFSHORE VOLUNTARY DISCLOSURE PROGRAM AND THE STREAMLINED PROGRAMS

- By : Parag Patel

…the United States for Streamlined Foreign Offshore Procedures, available at http://www.irs.gov/pub/irs-pdf/f14653.pdf. IRS Form 14654 – Certification by S. Person Residing Inside the United States Streamlined Domestic Offshore Procedures, available at…

IRS Letters and Notices Offering an Appeal Opportunity

- By : Parag Patel

There are many missed opportunities to solve tax problems with the IRS through the IRS Appeals office. Below is a list of the most common IRS letters and notices affording…

President Trump Revamps the IRS through his 2019 Taxpayer First Act

- By : Parag Patel

IRS Appeals process are mere guidelines and may not be followed by the IRS. Improvement of IRS Service The National Taxpayer Advocate, in her annual reports, has repeatedly criticized the…

IRS Announces New Rules for FBAR Penalties

- By : Parag Patel

…carried out by the IRS. The Office of Appeals serves as the administrative dispute resolution forum for any taxpayer contesting an IRS compliance action. It has long been Appeals’ mission…

IRS Passport Revocation or Denial for Unpaid Taxes

- By : Parag Patel

…the IRS, the IRS will let the State Department know. This takes about 30 days on the IRS’s end, but the IRS has not explained how long it takes the…

Resolving IRS disputes through audit reconsideration

- By : Parag Patel

…function within the IRS generally grants taxpayers the right to have their case heard by an independent representative of the IRS. Third, the additional tax assessed by the IRS must…

The IRS is Assessing Form 3520 Foreign Information Reporting Penalties

- By : Parag Patel

…to Levy and Notice of Your Right to a Hearing, or Letter 3172, Notice of Federal Tax Lien and Your Rights to a Hearing under IRC 6320. Appeals: IRS Appeals…

New IRS IRM with Updated Streamlined Filing Compliance procedures

- By : Parag Patel

IRS audits, IRS collections, IRS appeals and criminal investigations. The IRS recently internally changed the IRM for the IRS’ revised “streamlined” procedures for individuals who unintentionally fail to report foreign-source…

IRS list of “dirty dozen” tax scams

- By : Parag Patel

…Identity Protection Specialized Unit at 1-800-908-4490. A suspicious e-mail or an “IRS” Web address that does not begin with http://www.irs.gov should be forwarded to the IRS at phishing@irs.gov. Return Preparer…

Time Running Out for HSBC India accountholders sought by IRS

- By : Parag Patel

…does not in fact—issue IRS Forms 1099 reporting to its U.S. clients income paid in India. Nor does HSBC India file corresponding Forms 1099 with the IRS reporting the income…

IRS posts its “wins” involving offshore accounts

- By : Parag Patel

http://www.irs.gov/uac/Offshore-Tax-Avoidance-and-IRS-Compliance-Efforts Offshore Tax-Avoidance and IRS Compliance Efforts The IRS continues to uncover abusive tax-avoidance schemes involving offshore activity. Find information here pertaining to Union Bank of Switzerland (UBS). Aug. 19,…

The IRS has woken up.

- By : Parag Patel

…filed within each grouping has grown over the same time period.  (Internal Revenue Service Data Book, 2019; Table 17a; https://www.irs.gov/pub/irs-pdf/p55b.pdf).  The IRS has also embarked on a separate initiative to contact…

Post IRS Audit Strategic Options: The IRS’ 30 Day Letter

- By : Parag Patel

…Division — the taxpayer is granted 30 days in which to request a conference with the Appeals staff. Recent guidance to auditors provides that IRS Appeals will need to at…

IRS announces two new intriguing targeted enforcement campaigns

- By : Parag Patel

…Disclosure Program (OVDP) Compliance enforcement campaign The new Post OVDP Compliance enforcement campaign was recently announced as a result of IRS data analysis and suggestions from IRS employees. IRS employees…

For Tax Professionals: A Guide to the IRS’s Voluntary Disclosure Practice

- By : Parag Patel

IRS Commissioner Shulman has invited persons with unreported foreign accounts to come forward and avail themselves of the IRS’s Voluntary Disclosure Practice. That practice is described in the Internal Revenue…

Full Analysis of Updated 2012 OVDP Program

- By : Parag Patel

…who are subject to continuous IRS examination. Although the IRS announced the program in January as “open-ended,” the announcement indicated that the IRS may end the 2012 program at any…

IRS Updated Voluntary Disclosure Practice is a Game-Changer

- By : Parag Patel

…the lower non-willful FBAR penalty. Right to IRS Appeals An additional procedural change is that taxpayers who cannot reach an agreement with the IRS will retain the right to go…

Helpful Non-willful FBAR penalty case decided by court

- By : Parag Patel

…pre-assessment review, IRS nonetheless allowed him to contest it, and Mr. Moore had the opportunity to seek judicial review of all of IRS’s decisions. Finally, the court found that IRS’s…

IRS Offshore Voluntary Disclosure Programs Continue to Burden “Benign Actors” and Damage IRS Credibility

- By : Parag Patel

…the IRS’s letters. These reversals further erode the IRS’s credibility, and are more likely to reduce than to increase voluntary compliance. Moreover, the IRS has not adopted the National Taxpayer…

American Citizens Abroad (ACA) writes letter to IRS Commissioner regarding unfair offshore asset treatment

- By : Parag Patel

American Citizens Abroad (ACA) has written to IRS Commissioner Doug Shulman of the IRS to express the organization’s profound concern that he has not answered the Directive issued by National…

IRS’s four offshore programs have netted 39,000 taxpayers and over $5.5 billion

- By : Parag Patel

…estimated by one IRS commissioner to amount to several tens of billions of dollars, but no precise figure exists. The IRS has operated four offshore programs since 2003 that offered…

IRS Announces New Investigative Units

- By : Parag Patel

…the Panama Papers and other sources. Despite IRS budget cuts, IRS is also maintaining a physical presence internationally, with IRS attachés on the ground in Barbados, Bogota, Frankfurt, The Hague…

New IRS Enforcement Letters Warn of Cryptocurrency Non-Compliance

- By : Parag Patel

…and penalties,” said IRS Commissioner Chuck Rettig. “The IRS is expanding our efforts involving virtual currency, including increased use of data analytics. We are focused on enforcing the law and…

Increased IRS Enforcement Expected Against High-Income Taxpayers

- By : Parag Patel

…first report, concerning IRS compliance trends and enforcement activities, TIGTA said that the IRS collected $3.6 trillion in total revenue, more than any year previous and $99.1 billion more than…

2 recent IRS developments that will impact Indian Americans

- By : Parag Patel

…their filing obligations and now seek to come into compliance with the law.’ The IRS clarifies that this new procedure does not provide protection from criminal prosecution if the IRS

IRS Most Common Tax Notices and What They Mean

- By : Parag Patel

The IRS has redesigned its correspondence notices to be more “user friendly.” This is supposed to make their notices easier to understand and therefore allow responses to occur in a…

IRS examines jewelry, precious stones and metals businesses for compliance

- By : Parag Patel

…what can the IRS do in these investigations? The IRS is conducting Anti-Money Laundering examinations with experienced Bank Secrecy Act Fraud investigators. The investigations include specific IRS Information Document Requests…

IRS announces new Streamlined Filing Compliance Procedures

- By : Parag Patel

…New IRS Changes This alert discusses only some of the many changes made by the IRS. It is important to note that the IRS has the authority to change the…

Employee or Contractor?: The IRS’s New Voluntary Classification Settlement Program (VCSP)

- By : Parag Patel

When the IRS says “voluntary” it can sound scary. The IRS is unlikely to use this word unless the potential liability is serious. The IRS would much rather have you…

COURT AUTHORIZES SERVICE OF JOHN DOE SUMMONS SEEKING THE IDENTITIES OF U.S. TAXPAYERS WITH OFFSHORE ACCOUNTS AT CIBC FIRSTCARIBBEAN INTERNATIONAL BANK

- By : Parag Patel

…Henderson. The IRS summons seeks records of FCIB’s United States correspondent account at Wells Fargo N.A., which will allow the IRS to identify U.S. taxpayers who hold or held interests…