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Who are you partnering with for your Financial Institution’s BSA/AML Independent Testing?

Financial Institutions ought to design and evaluate compliance programs to meet BSA/AML requirements and to satisfy Bank Examiner expectations. A Financial Institution’s Compliance Programs must comply with the requirements...more

IRS issues FATCA Relief but not for All

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

Can you identify a Misappropriation Scheme?

Misappropriation is the use of property or funds of another person for an unauthorized purpose.  In misappropriation, the perpetrator steals or misuses an organization’s belongings and resources; usually without force.  The...more

Payers and Payees have Obligations to Comply with Backup Withholding

Backup Withholding requires a payer to “withhold tax” from payments that are not otherwise subject to withholding.  A Taxpayer (payee) may be subject to Backup Withholding if it...more

Wondering About The Tax Treatment Of A Cryptocurrency Hard Fork And Airdrop?

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

¿Su institución financiera utiliza un “Matrix” de enfoque basado en el riesgo de la OFAC?

El perfil de riesgo de la OFAC de una Institución Financiera se determina basado sus productos, servicios, clientes y ubicaciones geográficas.  Se requiere que un programa de cumplimiento OFAC de una Institución Financiera...more

Does your Financial Institution utilize OFAC’s Risk Based Approach Matrix?

A Financial Institution’s OFAC risk profile is determined based on its products, services, customers and geographic locations.  A Financial Institution’s OFAC compliance program is required to...more

Los Contadores Forenses son “Detectives Privados”

El entorno actual de cambio creciente, las presiones económicas, la globalización, la tecnología, el gobierno corporativo, el cumplimiento y la complejidad de las transacciones financieras son las fuerzas impulsoras del...more

Forensic Accountants are “Private Detectives”

The current environment of increasing change, economic pressures, globalization, technology, corporate governance, compliance and the complexity of financial transactions are driving forces behind fraud initiation. In...more

Indirect linkages to Tax Havens

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

Taxpayers, have you sold, received, exchanged or acquired Virtual Currency?

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

Why is it important to choose the right Power of Attorney for your IRS representation?

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

Did you know that the IRS has 59 Compliance Campaigns? Have your Audit Plan Ready!

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

IRS Initiates a Compliance Campaign for U.S. Persons with respect to Certain Foreign Corporations

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

Your Tax Home and Travel Expense Deductions

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 using Data Analytics to Uncover Criminal Arrangements

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

When do you need an IRS Certifying Acceptance Agent?

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

Does it make sense to go from an S-Corp to a C-Corp?

IRS defines an S-Corp as a corporation whose shareholders make the election to pass corporate income, losses, deductions, and credits through to their shareholders for federal tax purposes.  The owners of an S-Corp report the...more

What is an Abusive Tax Trust?

In a “legitimate” Trust, the ownership and control of the Trust assets and income is “separate” from a Settlor’s control and benefit. IRS has been reporting that Trusts are used for abusive tax schemes to hide true ownership...more

An effective compliance program can help diminish an organizational criminal fine

On April 30, 2018, the Criminal Division of the US Department of Justice (DOJ) released a guidance document regarding corporate compliance programs.  The guidance looks at the adequacy and effectiveness of compliance programs...more

If you Exchange Virtual Currency, you are a Money Transmitter and must comply with the Bank Secrecy Act (BSA)

FinCEN defines a Money Service Business (MSB) as any person DOING BUSINESS, whether or not on a regular basis or as an organized business concern, in one or more of the following capacities...more

Understanding how Taxpayers may Appeal to the IRS Office of Appeals

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

Penalty of $25,000 for Foreigners with a 25% ownership stake or control of a U.S. legal entity that fail to file Form 5472

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

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