News & Analysis as of

Reporting Requirements Internal Revenue Service

Failure to Disclose Adjusted Basis on Disclosure Form Costs Taxpayer $33M+ Charitable Deduction

by Charles (Chuck) Rubin on

Under Treas. Regs. §1.170A-13, taxpayers making substantial noncash charitable contributions are required to disclose information regarding the contribution on Form 8283. ...more

Treasury Gives Taxpayers Extra Year to Meet Related-Party Debt Documentation Requirements; Per Se Equity Rule Unchanged

by Latham & Watkins LLP on

The one-year postponement assists taxpayers that are developing compliance systems, amidst broader government review of the related-party debt regulations. On July 28, 2017, the US Department of the Treasury (Treasury) and...more

Overview of IRS Penalties for Individuals with Foreign Bank Accounts and Investments

by Blank Rome LLP on

Earlier this spring, the Internal Revenue Service ("IRS") Large Business and International Division identified several "campaigns" or areas where it plans to focus its audit resources. One campaign involved taxpayers who...more

Federal Tax Treatment of Employer-Provided Identity Protection Services

In the wake of several recent high-profile security breaches, employers are increasingly viewing identity theft protection as an essential employee benefit for employees. According to Willis Towers Watson’s 2016 voluntary...more

Why you need EXPERT ADVICE if you have a PFIC and you are out of Compliance!

by Foodman CPAs & Advisors on

Taxpayers need to rely on the expert professional advice of a tax specialist for the treatment of Passive Foreign Investment Companies (PFICs) during Offshore Voluntary Disclosure Program (OVDP) reporting. PFIC computations...more

FBAR Penalties Now Adjusted for Inflation: Abatement/Mitigation Still Possible

If you haven’t filed your Report of Foreign Bank and Financial Accounts (FBARs) on a timely basis, you could be at risk of a higher civil penalty assessment. Inflation-adjusted FBAR penalties are now in effect....more

Tax-Exempt Does Not Mean Exempt From Filing Tax Returns

May 15 was the filing deadline for nonprofits operating on a calendar year that are required to file Form 990-series information returns. Many nonprofits mistakenly believe that they are not required to file returns with the...more

2017 OVDP Declines and Withdrawals Campaign: Certain U.S. Taxpayers at Risk of Audit

In 2016, the Treasury Inspector General for Tax Administration (TIGTA) released a report which assessed how well that IRS was managing the Offshore Voluntary Disclosure Program (OVDP). OVDP is one of the programs taxpayers...more

Three More Countries Will Now Provide IRS Information On Bank Interest Paid To Nonresident Aliens

by Fox Rothschild LLP on

The IRS recently released Revenue Procedure 2017-31 which adds Belgium, Columbia and Portugal to the list of participates in the automatic exchange of information on bank interest paid to nonresident alien individuals for...more

Court Denies Motion For Preliminary Injunction Prohibiting The IRS From Enforcing The Micro-Captive Disclosure Requirements In...

by Fox Rothschild LLP on

On November 1, 2016, the IRS issued Notice 2016-66 imposing new reporting requirements on micro-captives and their material advisors (see prior post describing the Notice). On March 27, 2017, CIC Services, LLC and Ryan, LLC...more

Applying Overpayments of Tax to Tax and the Offshore Penalty in the OVDP Program

by Charles (Chuck) Rubin on

The OVDP program allows taxpayers to remedy deficient disclosure filings relating to offshore accounts for a fixed penalty amount. As part of the program, taxpayers must file either original or amended tax returns which...more

US Banks wanting to be ahead of the FATCA game must master international tax compliance

by Foodman CPAs & Advisors on

The terms FDAP (Fixed, Determinable Annual and Periodical Income) and ECI (Effectively Connected Income) are expansive terms. They are the backbone behind the tax withholding, and reporting requirements imposed on US Banks...more

Developing a Strategy to Fight FBAR Penalties

by Carlton Fields on

Since 2009, the number of FBAR penalties imposed for failures to report foreign bank accounts and the size of the penalties have both increased dramatically. Originally published in The Tax Advisor....more

IRS Implementation of ACA’s Employer Shared Responsibility Provision Falls Short Based on the Results of a Recent Audit

by McDermott Will & Emery on

Based on a recent audit conducted by the Treasury Inspector General for Tax Administration (TIGTA), the IRS’ processes and procedures to ensure compliance with the employer information reporting requirements mandated by the...more

IRS Implementation of ACA’s Employer Shared Responsibility Provision Falls Short Based on the Results of a Recent Audit

by McDermott Will & Emery on

Based on a recent audit conducted by the Treasury Inspector General for Tax Administration (TIGTA), the IRS’ processes and procedures to ensure compliance with the employer information reporting requirements mandated by the...more

IRS Updates FATCA FAQs, Addresses January Temporary Regulations

by Proskauer - Tax Talks on

On April 6, 2017, the Internal Revenue Service (the IRS) added three new frequently asked questions to its Foreign Account Tax Compliance Act (“FATCA”) compliance page, which is available only online. These additional FAQs...more

Treasury Releases Report on Employer Mandate Enforcement

by Littler on

On April 7, 2017, the Treasury Inspector General for Tax Administration (TIGTA) published a report on the “Assessment of Efforts to Implement the Employer Shared Responsibility Provision.”  This report1 provides clues to the...more

Civil Forfeiture Enforcement Under Fire – Part I

by Ballard Spahr LLP on

Forfeiture actions by Internal Revenue Service Criminal Investigation (IRS CI) based on alleged structuring activity have come under fire, yet again. Specifically, the Treasury Inspector General for Tax Administration (TIGTA)...more

New Reporting Regime: Estates Who Have to File Federal Estate Tax Returns Need to be Aware of New Basis Consistency Law

by Bowditch & Dewey on

On July 31, 2015, the Surface Transportation and Veterans Health Care Choice Improvement Act of 2015 introduced new tax law that affects executors who are required to file a federal estate tax return and beneficiaries...more

IRS Synchs Excise Tax to DOL's Enforcement Policy on Fiduciary Rule

by Burr & Forman on

The IRS released guidance this week announcing that it will not apply IRC § 4975 excise taxes (15% on prohibited transactions) and related reporting requirements “with respect to any transaction or agreement to which the...more

Getting Into Compliance with Your Foreign Account Reporting, Part II

by Moskowitz LLP on

In Part I, we listed some of the penalties associated with the failure to report foreign accounts, and what is widely regarded as the best option for coming into compliance – the Offshore Voluntary Disclosure Program (OVDP)....more

March 2017: Client Alert

by Moskowitz LLP on

2016 Proof of Health Insurance: the Form 1095 Wrinkle - Under the current Affordable Care Act (ACA), all Americans must have health insurance. If you receive your health insurance through the ACA marketplace or from...more

Reporting Foreign Income: Four Common Misconceptions

by Moskowitz LLP on

The U.S. government has stringent reporting requirements when it comes to foreign assets and income, but many people are still not coming into compliance based on some mistaken beliefs. Here are four common misconceptions...more

Food and Beverage Law Update: March 2017

by Holland & Knight LLP on

Legalized Drug Use Impacts the Food and Beverage Industry - In the November 2016 general election, voters in Arkansas, Florida and North Dakota amended their state constitutions to authorize the use of marijuana for...more

Strict Charitable Contribution Substantiation Requirements Trip Up Another Taxpayer

by Charles (Chuck) Rubin on

Taxpayers making contributions to charities that seek a charitable deduction have a myriad of reporting and receipt requirements to comply with. Code §170(f)(12) imposes additional requirements as to contributions of motor...more

372 Results
|
View per page
Page: of 15
Cybersecurity

"My best business intelligence,
in one easy email…"

Your first step to building a free, personalized, morning email brief covering pertinent authors and topics on JD Supra:
Sign up using*

Already signed up? Log in here

*By using the service, you signify your acceptance of JD Supra's Privacy Policy.
*With LinkedIn, you don't need to create a separate login to manage your free JD Supra account, and we can make suggestions based on your needs and interests. We will not post anything on LinkedIn in your name. Or, sign up using your email address.