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Choose Opt Out Option Wisely in Offshore Voluntary Disclosure Program

Since 2009, the Internal Revenue Service has offered a variety of offshore voluntary disclosure programs (collectively, OVDP) under which a U.S. taxpayer can disclose previously undisclosed offshore activities. However, these...more

Procedural Oversight by IRS Turns Out to Be a Good Weapon for Taxpayers

Good news for taxpayers: a procedural requirement on the IRS’s part that historically had not been strictly enforced has recently risen above the surface. Taxpayers under audit, in particular those litigating in Tax Court,...more

Updates on Denial or Revocation of Passport in Case of Certain Tax Delinquencies

In 2015, a new law was passed to allow the IRS to use travel as a way to collect taxes by placing restrictions on a U.S. person’s passport if such U.S. person owes seriously delinquent tax debt. Generally, if a U.S. taxpayer...more

IRS and DOJ are Reviewing and Scrubbing Offshore Accounts Data to Build Civil and Criminal Cases

During the June 24, 2016 Tax Controversy Conference held at New York University, officials from both the Department of Justice (DOJ) and the Internal Revenue Service (IRS) emphasized their focus on analyzing the avalanche of...more

Deadline: Foreign Bank Account Reports Due June 30, 2016

Any U.S. person who has a financial interest in or signature authority over one or more foreign financial accounts with an aggregate value over $10,000 (on any day of the year) must report the accounts to the Treasury...more

Passport May Be Revoked If Owing More Than $50,000 in Taxes

On December 4, 2015, the Fixing America’s Surface Transportation Act (the FAST Act) was signed into law. Among other items, the FAST Act gives the Internal Revenue Service (IRS) and the Department of the Treasury power to...more

Updates on Offshore Financial Account Compliance and Small Business Audit Considerations

Recently, IRS officials, including Commissioner John Koskinen, have stated that the streamlined filing program for the disclosure of previously unreported foreign financial accounts would not last forever and would end at...more

FIRPTA Withholding Tax Rate to Increase 15 Percent on February 2016

On December 18, 2015, the Protecting Americans from Tax Hikes Act (the Act) was signed into law. Among other items, the Act materially amends the Foreign Investment in Real Property Tax Act of 1980 (FIRPTA) to increase the...more

Possible Changes to IRS Audits of High Income Individuals

The Internal Revenue Service (IRS) is considering increasing the income threshold to identify a taxpayer as being wealthy enough to be audited by the IRS’s High-Income and High-Wealth Strategy Team. The recommendation to do...more

12/13/2015  /  Audits , High Net-Worth , Income Taxes , IRS

Changes in Tax Return and FBAR Due Dates and Extensions

The deadline for filing tax returns and Foreign Bank Account Report (FinCEN Form 114) (FBAR) has been changed by the Surface Transportation and Veterans Health Care Choice Improvement Act of 2015. Below is a brief summary of...more

Innocent Spouse Relief Granted Due to Spousal Abuse Even If Requesting Spouse Had Knowledge of Tax Deficiency

In a recent Tax Court case, innocent spouse relief was granted to a Florida taxpayer to relieve her from over $400,000 in tax deficiency and penalties. Tax Court typically is reluctant to grant innocent spouse relief when the...more

$10,000 in Cash Receipts? Heightened Penalties for Failure to File Form 8300 Within 15 Days

Any person who, in its trade or business, receives cash in the amount of more than $10,000 in a single transaction or a series of related transactions must file Form 8300, Report of Cash Payments Over $10,000, Received in a...more

Cross-Border Activities: Benefits of Filing “Protective” Returns

With the increasing focus by the Internal Revenue Service (IRS) on offshore activities, it is important to understand the tax return and information return filing obligations that may be associated with such activities....more

IRS New Guidance Significantly Reduces Maximum FBAR Penalties

To moderate the draconian Foreign Bank and Financial Accounts (FBAR) violation penalties under Title 31 of the U.S. Code, the IRS just published guidance that significantly reduces willful and non-willful FBAR violations....more

June 30 Deadline: Foreign Financial Account and Asset Reporting Obligations

Do you maintain bank accounts outside the U.S.? Do you own any foreign financial assets, such as foreign stock or a loan to a foreign person? If you do, you should be aware that you may have extra reporting obligations to the...more

Innocent Spouse Relief and Recent Guidance

Generally, when you and your spouse file joint income tax returns, the law makes both you and your spouse responsible for the entire tax liability. This is called joint and several liability. Both spouses remain 100 percent...more

DEADLINE: Foreign Bank Account Reports Due June 2015

Any U.S. person who has a financial interest in or signature authority over one or more foreign financial accounts with an aggregate value over $10,000 (on any day of the year) must report the accounts to the Treasury...more

5/18/2015  /  FBAR , Filing Deadlines , FinCEN , U.S. Treasury

Deadline: Foreign Bank Account Reports Due June 30, 2014

Any U.S. person who has a financial interest in or signature authority over one or more foreign financial accounts with an aggregate value over $10,000 (on any day of the year) must report the accounts to the Treasury...more

Is Your Tax Return Being Audited? Know What To Do!

For most people, when their income tax returns are being selected for examination by the IRS, their first reaction is panic. No need to worry. In such a situation, you should know what to do next, what to expect next, and...more

Plan Sponsors of 401(k) Plans/Pension Plans: Must Recognize Same Sex Married Couples Effective September 16, 2013

On August 29, 2013, the Internal Revenue Service (IRS) ruled that for federal tax purposes, spouse includes an individual who is legally married to a same-sex individual under state law. This Revenue Ruling 2013-17 has a...more

FBAR Filing By Third Parties and Spouses

U.S. persons who maintain bank accounts overseas with high balances are required to file the Foreign Bank and Financial Accounts Reports (FBARs) each year. Effective July 1, 2013, all FBARs must be filed electronically using...more

8/27/2013  /  E-Filing , FBAR , FinCEN

Deadline: Foreign Bank Account Reports Due June 30, 2013

Any U.S. person who has a financial interest in or signature authority over one or more foreign financial accounts with an aggregate value over $10,000 (on any day of the year) must report the accounts to the Treasury...more

Built-In Gains Shortened Holding Period Extended By New Tax Bill

Generally, if a corporation converts from a C corporation to a subchapter S corporation, the corporation must hold its appreciated assets for at least 10 years or, otherwise, the corporation must pay taxes (which could be as...more

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