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

- By : Parag Patel

…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 http://www.irs.gov/pub/irs-pdf/f14654.pdf.   requires…

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…

IRS Updates Process for FAQs

- By : Parag Patel

IRS finally figured out that taxpayers need help with IRS frequently asked questions (FAQs). IRS places FAQs on its website and taxpayers naturally read them and believe them to be…

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…

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…

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…

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’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…

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 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…

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…

The IRS’ Complex Statute of Limitations

- By : Parag Patel

IRS collections officers what the IRS system has calculated as the statute of limitations for tax collection. The general rule is that the IRS must collect taxes within 10 years…

Welcome news from IRS for late Form 3520 penalties

- By : Parag Patel

On its website, the IRS has announced that it has retired its Form 3520/3520A compliance campaign. In welcome relief for taxpayers, the IRS also indicates in updated IRM procedures that it…

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…