The IRS continues to process electronic tax returns, issue direct deposit refunds and accept electronic payments while simultaneously granting additional, broad tax filing and payment deadline relief to all Taxpayers that...more
When a Tax Professional files an electronic Return on behalf of a Taxpayer, the Tax Professional obtains Forms 8878 and 8879 as declaration documents required by the IRS on behalf of a Taxpayer. Forms 8878 and 8879 are...more
IRS wants to be part of the solution to improve the lives of all people in the US. On March 25, 2020, IRS released the “IRS People First Initiative” providing immediate relief to help people facing uncertainty over taxes....more
The distribution of economic impact payments will begin in the next three weeks (weeks of April 6th, 13th and 20th of 20202). According to the IRS, the payments will be distributed automatically, with no action required for...more
In November, 2019 the IRS and the Office of Foreign Assets Control (OFAC) signed a Memorandum of Understanding (MOU). The MOU outlines an understanding between the IRS and OFAC with respect to reviews conducted by the IRS...more
IRC Section 965 (Treatment of Deferred Foreign Income Upon Transition to Participation Exemption System of Taxation) was part of the TCJA enacted on December 22, 2017. ...more
2/7/2020
/ Double Taxation ,
Foreign Corporations ,
Foreign Earned Income ,
Internal Revenue Code (IRC) ,
International Tax Issues ,
IRS ,
Reporting Requirements ,
Tax Cuts and Jobs Act ,
Tax Liability ,
Tax Planning ,
Tax Returns ,
Transition Tax
U.S. Taxpayers (includes a citizen, permanent resident, corporation, partnership, limited liability company, trust and estate) are required to file a Report of Foreign Bank and Financial Accounts (FBAR) if they have...more
2/7/2020
/ FBAR ,
FinCEN ,
Foreign Bank Accounts ,
Income Taxes ,
IRS ,
Offshore Banks ,
Offshore Funds ,
Reporting Requirements ,
Tax Court ,
Tax Evasion ,
Tax Liability ,
Tax Penalties ,
Tax Planning ,
Tax Returns
On September 6, 2019, IRS announced Relief Procedures for Certain Former Citizens. These are procedures for certain persons who have relinquished, or intend to relinquish, their United States citizenship, who wish to come...more
1/17/2020
/ Citizenship ,
Expatriates ,
FATCA ,
FFI ,
Filing Requirements ,
Income Taxes ,
IRS ,
Popular ,
Reporting Requirements ,
Tax Code ,
Tax Liability ,
Tax Planning ,
Tax Relief
On 10/9/19, IRS issued Rev. Rul. 2019-24 addressing the issues of a Taxpayer having gross income under § 61 of the Internal Revenue Code as a result of a hard fork of a cryptocurrency that the Taxpayer owns if the Taxpayer...more
12/13/2019
/ Bitcoin ,
Blockchain ,
Cryptocurrency ,
Distributed Ledger Technology (DLT) ,
Financial Transactions ,
Gross Proceeds ,
Income Taxes ,
Internal Revenue Code (IRC) ,
IRS ,
Popular ,
Tax Liability ,
Tax Planning ,
Virtual Currency
On July 2, 2018, the IRS introduced a Compliance Campaign directed at Section 965 (Transition Tax) of the Internal Revenue Code (IRC). In its original launch, the Section 965 Campaign stated that U.S. shareholder are...more
The U.S. income tax system is based on the idea of voluntary taxpayer compliance. It is the taxpayer’s responsibility to report all reportable worldwide income. Some people attempt to evade paying taxes by failing to report...more
During the month of October 2019, IRS issued Revenue Ruling 2019-24, FAQ’s on Virtual Currency Transactions and a DRAFT Form of Schedule 1, which, for the first time presents the question: “At any time during 2019, did you...more
11/15/2019
/ Bitcoin ,
Capital Gains ,
Cryptocurrency ,
Digital Currency ,
Filing Requirements ,
Financial Transactions ,
Income Taxes ,
Investment ,
IRS ,
Popular ,
Reporting Requirements ,
Tax Liability ,
Tax Planning ,
Tax Returns ,
Virtual Currency
An individual that provides information to an attorney may normally assume that the information provided to the attorney will be kept confidential under the attorney-client privilege. That said, according to the Internal...more
Circular 230 (Regulations Governing Practice before the Internal Revenue Service) governs those that are authorized to practice in front of the IRS: Attorneys, CPAs and Enrolled Agents. Practicing in front of the IRS means...more
IRS Large Business and International (IRS LBI) currently has 59 Active Compliance Campaigns. The purpose of the IRS compliance campaign strategy is to redefine large business compliance work and build a supportive...more
10/11/2019
/ Cooperative Compliance Regime ,
Expatriates ,
FATCA ,
Foreign Earned Income ,
Foreign Tax Credits ,
Income Taxes ,
IRS ,
Life Insurance ,
MVPD ,
Noncompliance ,
Offshore Banks ,
OVDP ,
S-Corporation ,
Swiss Banks ,
Tax Audits ,
Tax Credits ,
Tax Planning ,
Tax Treaty ,
TEFRA ,
Variable Annuities ,
Virtual Currency
On June 20, 2019, the National Taxpayer Advocate (TA), an independent organization within the IRS that helps taxpayers and protects taxpayer rights, issued a final Report to Congress. A section of the report focused on the...more
9/27/2019
/ Amended Rules ,
Burden of Proof ,
Criminal Liability ,
Criminal Penalties ,
FBAR ,
Foreign Assets ,
IRS ,
Offshore Funds ,
OVDP ,
Reporting Requirements ,
Voluntary Disclosure
IRS Form 5471 is used by certain U.S. persons who are officers, directors, or shareholders in certain foreign corporations and must be attached to a covered Taxpayer’s Tax Return. On April 16, 2019, IRS announced the...more
9/6/2019
/ Controlled Foreign Corporations ,
Cooperative Compliance Regime ,
Corporate Officers ,
Directors ,
Filing Requirements ,
Foreign Corporations ,
Income Taxes ,
IRS ,
Shareholders ,
Stock Ownership ,
Tax Planning ,
Tax Returns
The Internal Revenue Code (IRC) permits a U.S. Taxpayer to deduct “certain travel expenses” when traveling away from home on business. Taxpayers ought to keep close attention to a travel expense deduction and ensure that...more
IRS-Criminal Investigation (IRS-CI) is a federal agency department specifically authorized to investigate and prosecute federal income tax crimes. IRS-CI uses data analytics such as models, algorithms, and the millions of...more
8/19/2019
/ Analytics ,
Anti-Money Laundering ,
Criminal Investigations ,
FATCA ,
Financial Crimes ,
Foreign Financial Institutions (FFI) ,
IRS ,
John Doe Investigation ,
Tax Crimes ,
Tax Fraud ,
Tax Planning
There are foreign national Individuals and other foreign Persons that do not have or do not qualify for a Social Security Number (SSN) but need a Taxpayer Identification Number (TIN) to file certain tax forms and schedules...more
IRS has an Office of Appeals (OOA) that operates as an “independent” organization within the IRS. The goal of the OOA is to help Taxpayers resolve their tax disputes through an informal, administrative process, and through...more
On April 18, 2019, IRS released the IRS Integrated Modernization Business Plan April 2019 (Plan) - a six year Plan designed to modernize the IRS’ technology systems, improve Taxpayer services and protect Taxpayer data. ...more
7/9/2019
/ Business Taxes ,
Client Services ,
Corporate Taxes ,
Cybersecurity ,
Data Protection ,
Income Taxes ,
Integrated Modernization Business Plan ,
IRS ,
Modernization ,
Multinationals ,
Small Business ,
Tax Exempt Entities
The IRS produces a yearly list of Tax Scams known as the Dirty Dozen that Taxpayers may encounter. IRS reiterates that Tax Scams put Taxpayers at Risk when it releases its list of Dirty Dozen Tax Scams. These aggressive...more
7/8/2019
/ Charitable Deductions ,
Failure to Report ,
False Documentation ,
FATCA ,
Identity Theft ,
IRS ,
Offshore Funds ,
Phishing Scams ,
Qualified Disaster Relief Payments ,
Risk Mitigation ,
Tax Credits ,
Tax Deductions ,
Tax Penalties ,
Tax Preparers ,
Tax Scams ,
Tax Shelters ,
Unsolicited Phone Calls
Form 5472 is an Information Return of a 25% Foreign-Owned U.S. Corporation or a Foreign Corporation Engaged in a U.S. Trade or Business. The purpose of Form 5472 is to provide information when “reportable transactions” occur...more
7/1/2019
/ Beneficial Owner ,
Disregarded Entities ,
Financial Transactions ,
Foreign Corporations ,
Foreign Persons ,
Foreign-Owned Corporations ,
IRS ,
Reportable Events ,
Required Forms ,
Tax Cuts and Jobs Act ,
Tax Penalties ,
Tax Planning ,
Tax Reform
An EIN is also known as a Federal Entity Tax Identification Number (EIN) and is used to identify a business entity such as a sole proprietorship, corporation, partnership, estate, trust, and other entities for tax filing and...more