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On June 18, 2014, the IRS announced sweeping changes to the 2012 Offshore Voluntary Disclosure Program (OVDP). Since that time, additional clarification on procedural requirements has been issued. Most recently, as of August...more
As you may have read, the Internal Revenue Service (“IRS”) recently announced changes to its offshore voluntary disclosure programs and announced new options for taxpayers to come into compliance with their U.S. tax...more
In a major change to the Offshore Voluntary Disclosure Program, the streamlined filing compliance procedures with their 5% penalty, has been opened up to non-willful violators that reside in the U.S. This is to be contrasted...more
On Wednesday, May 28, 2014, a jury in Miami issued a verdict against a taxpayer for $2.2 million in fees, interest, and civil penalties for willfully failing to file foreign bank account reports (FBARs) for his Swiss bank...more
Before the ink on the Affordable Care Act was dry, prudent employers were analyzing the law to identify ways to save money and avoid many of the punitive aspects of the law....more
A district court in the Northern District of California has held that the officer of a now-defunct corporation is personally responsible for the Trust Fund Recovery Penalty based upon the company’s failure to collect, account...more
The IRS recently released an FBAR Reference Guide, pertinent portions of which are reprinted below.
Who Must File the FBAR?
A United States person must file an FBAR if that person has a financial interest in or...more
Now that the IRS has issued final regulations under Section 4980H, the so-called “pay or play” provision of the Affordable Care Act, employers are deciding how to determine whether employees are full-time (30 hours or more a...more
Beginning January 1, 2015, the large employer mandate of the Affordable Care Act (ACA) requires that all full-time employees be offered minimum essential, affordable coverage. Penalties will be assessed for each month that a...more
On December 3, 2013, the U.S. Supreme Court unanimously reversed the U.S. Court of Appeals for the Fifth Circuit and held that (1) a federal district court in a partnership-level proceeding had jurisdiction to determine the...more
IRS Explains Federal Tax Consequences of Windsor Case Regarding Same-Sex Marriages -
In our last report (Vol. 8, No. 3, September 2013), we told you about the recent Windsor case, in which the Supreme Court held...more
Employers and plan sponsors must comply with numerous filing and notice deadlines for their retirement and health and welfare plans. Failure to comply with these deadlines can result in costly penalties and excise taxes. To...more
In This Issue:
- Labor and Employment and ERISA Class Actions After Wal-Mart and Comcast — Practice Points for Defendants (Part I – Commonality)*
- Agencies Release Guidance on HRAs, FSAs, and Employer Payment...more
Lawyers in every area run into clients who admit that they have not filed their tax returns. Among the many questions raised by this information are the following three, which come up nearly every time. This outline gives...more
- The IRS has signaled its intent to prosecute more small businesses for relatively low-value tax violations.
- In doing so, the IRS has increased its reliance on data-driven analyses of the...more
The Internal Revenue Service has issued proposed regulations on reporting requirements under the Affordable Care Act (ACA). The regulations, released on September 9, 2013, address two separate ACA reporting requirements: one...more
The U.S. Department of the Treasury and the Internal Revenue Service have published proposed rules establishing reporting requirements for employers and insurers under the Affordable Care Act (“ACA”), or Obamacare....more
On July 2, 2013, the Treasury Department made a surprise announcement that enforcement of the Employer Shared Responsibility Mandate, a provision of the Patient Protection and Affordable Care Act ("PPACA"), would be delayed...more
Health Care Reform: IRS Transitional Relief Delays Pay or Play Reporting and Penalties -
As we reported in an alert on July 3, the IRS has provided transitional relief to employers that delays pay or play reporting and...more
On July 9, 2013, the U.S. Treasury Department and Internal Revenue Service (“IRS”) issued formal guidance (IRS Notice 2013-45; herein, the “Notice”)1 that provides for a one year delay until 2015 with respect to (i) certain...more
Taxpayers are required to disclose their ownership interests in foreign bank and financial accounts by filing a Form TD F 90-22.1, ...more
On July 9, the Internal Revenue Service (IRS) released Notice 2013-45 (the Notice), granting transition relief from the “Employer Shared Responsibility” provisions and certain health plan reporting requirements under the...more
On the heels of last week’s announcement that the Affordable Care Act’s (ACA) reporting requirements and Play or Pay penalties will not go into effect until 2015, the IRS has released transition relief clarifying that the...more
Often taxpayers who have not filed Reports of Foreign Bank or Financial Accounts (FBAR’s) will claim that they do not have records of their offshore accounts, because the accounts are maintained by third parties. In many...more
Carl R. Zwerner of Miami, Florida, is facing nearly $3.5 million in civil penalties for failing to report a Swiss bank account, according to a lawsuit filed by the Justice Department (United States v. Zwerner, S.D. Fla., No....more
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