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What Should I Do if I Missed the FBAR Filing Deadline?

Missing any deadline is stressful. But missing a tax deadline is more so. Per the Bank Secrecy Act (Title 31 of the U.S. Code), certain taxpayers must file so-called FBARs (currently FinCEN Form 114) with the government...more

How Do I Know if I Have an IRS Form 3520/3520-A Filing Obligation?

Interests in or transactions with foreign trusts can cause headaches for federal income tax purposes. Depending on the interest or transactions at issue, U.S. citizens or residents may have to file a Form 3520, a Form...more

How to Successfully Fight the Section 6721(e) Intentional Disregard Penalty

Section 6721 provides the IRS with authority to impose civil penalties against taxpayer-employers who fail to timely file correct information returns (e.g., Forms W-2/W-3 and Forms 940/941). Under section 6721’s three-tiered...more

Common Mistakes in Submitting an IRS Streamlined Filing Compliance Procedure Submission: And a Discussion of Professional...

For one reason or another, I had several calls last year with attorneys and others regarding IRS Streamlined Filing Compliance Procedure submissions gone wrong. In most cases, it was evident that the tax professional had...more

A Summary of the IRS’ Streamlined Filing Compliance Procedures

The IRS’ streamlined filing procedures were first offered by the IRS on September 1, 2012. Since that time, the IRS has made several revisions. A current summary of the IRS’ Streamlined Filing Compliance Procedures is...more

How to Successfully Request IRS Penalty Relief

Federal tax penalties have always been an IRS priority.  But, perhaps more so today than three decades ago.  For example, in 1987, the IRS reported that it had assessed penalties of approximately $14 billion.  Compare that...more

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