News & Analysis as of

Voluntary Disclosure Tax Liability

Mayer Brown

Brazilian IRS Program Incentivizes Disclosure of Certain Tax Liabilities

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On April 3, 2024, the Brazilian Internal Revenue Service (“Brazilian IRS”) published Normative Instruction RFB No. 2,184 (“IN/RFB No. 2,184/2024“), regulating a special program to incentivize the voluntary disclosure of...more

Foodman CPAs & Advisors

IRS Updates Its Voluntary Disclosure Program, And It Includes Crypto

The IRS wants to encourage Voluntary Disclosure participation and reduce Taxpayer uncertainty, but its current Voluntary Disclosure Program is not set up for success according to the 2021 National Taxpayer Advocate Annual...more

Freeman Law

IRS Voluntary Disclosures and Criminal Employment Tax Violations

Freeman Law on

Taxpayers who employ workers have obligations under federal law to withhold and remit federal employment taxes to the IRS. In addition to this withholding and payment requirement, federal law also imposes certain reporting...more

Freeman Law

The Evolving Standard of “Willfulness” in FBAR Cases: Where are We Now?

Freeman Law on

The concept of “willfulness” is an important one in the FBAR civil penalty context. Indeed, a taxpayer’s willful failure to file a timely and accurate FBAR may result in significant penalties: the higher of 50-percent of...more

McDermott Will & Emery

Key Takeaways | Cryptocurrency Global Tax Enforcement: What Investors and Companies in the Industry Need to Know NOW

McDermott Will & Emery on

During a recent program discussing the latest government enforcement efforts related to cryptocurrency, we spoke with Gary Alford, one of the leading Internal Revenue Service (IRS) agents in their crypto enforcement efforts,...more

McDermott Will & Emery

[Webinar] Cryptocurrency Global Tax Enforcement: What Investors and Companies in the Industry Need to Know NOW - June 28th, 12:00...

McDermott Will & Emery on

Following the US Internal Revenue Service’s (IRS) announcement of “Operation Hidden Treasure,” companies and individuals should prepare for increased scrutiny of virtual currency transactions. Unveiled in March, the operation...more

Gray Reed

Taxpayer Guidelines for Cryptocurrency in 2021

Gray Reed on

Cryptocurrency is more accessible than ever before. Banks are continuing to both implement procedures for and, in some cases, develop their own cryptocurrencies. Paypal allows users in the U.S. to buy, sell and hold select...more

Freeman Law

State and Local Tax Voluntary Disclosure

Freeman Law on

This article is the second of a three-part series regarding the State and Local Tax consequences of doing business in multiple states.  This article will discuss Voluntary Disclosure, Part 1 discussed Nexus and Part 3 will...more

Foodman CPAs & Advisors

What can I do if I willfully failed to comply with my tax obligations?

Foodman CPAs & Advisors on

Voluntary compliance is the foundation of the US tax system. Although the majority of US Taxpayers voluntarily comply with their obligations, some fail to do so.    ...more

Williams Mullen

Williams Mullen's Comeback Plan: Part I – State & Local Tax (SALT) Compliance During COVID-19: What to Do When You’re Behind

Williams Mullen on

Tax partners Stephanie Lipinski Galland and Kyle Wingfield summarize what you can do if you have not filed your state and local taxes or if you are unable to pay your tax bills due to the COVID-19 pandemic. Topics include...more

Foodman CPAs & Advisors

No deje que el IRS llegue a Usted Primero

Los Contribuyentes Estadounidenses con activos e ingresos financieros extranjeros no declarados corren el riesgo de que el Gobierno determine si su conducta fue intencional o no intencional.  ...more

Burr & Forman

IRS Releases New Guidance on Voluntary Tax Disclosures

Burr & Forman on

A bedrock of IRS administrative practice has been the voluntary disclosure. Where an individual or business has not filed tax returns or believes they may have criminal tax exposure for prior actions, IRS procedures have...more

Foodman CPAs & Advisors

IRS gives Internal Revenue Manual Voluntary Disclosure Consideration if…….

Foodman CPAs & Advisors on

When IRS reviews a criminal tax case, consideration is given to various factors such as whether a voluntary disclosure was made, whether prosecution exists, the health, age and mental condition of the Taxpayer and whether a...more

Butler Snow LLP

5 Common Tax Misconceptions Facing U.S. Persons Living Outside the U.S.

Butler Snow LLP on

Living abroad can be a wonderful opportunity for many U.S. Persons, but a few commonly misunderstood aspects of the U.S. tax system directly impact such “expats,” often to their financial detriment. Here are the five most...more

Burr & Forman

IRS Announces End to Foreign Bank Account Disclosure Program: What Can You Do Now If You Still Have Unreported Foreign Bank...

Burr & Forman on

The IRS recently announced it will be shutting down its successful Offshore Voluntary Disclosure Program (OVDP) for unreported foreign bank accounts and income. The program will end September 28, 2018. Under the OVDP, first...more

Sheppard Mullin Richter & Hampton LLP

Limited-Time Tax Amnesty for Marketplace Sellers

The Multistate Tax Commission (“MTC”) has implemented a limited-time voluntary disclosure initiative for online marketplace sellers (the “VDI”). The VDI creates an opportunity in many states to have a retailer’s historic...more

Ballard Spahr LLP

PA Tax Update: Amnesty Program and SUT Change

Ballard Spahr LLP on

Pennsylvania has a tax amnesty program that will run from April 21, 2017, to June 19, 2017. Even with many limitations on participation, this program may provide value to eligible taxpayers who have unfiled Pennsylvania tax...more

Pierce Atwood LLP

New Hampshire Lowers Tax Rates, Creates Amnesty and Voluntary Disclosure Programs

Pierce Atwood LLP on

After lengthy negotiations between legislators and Governor Maggie Hassan, New Hampshire enacted significant tax changes, including a cut to business tax rates, an increase in the research and development tax credit, and the...more

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