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

September 2019

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 approval of three additional

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Your Tax Home and Travel Expense Deductions

August 2019

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 it accurately correlates with a

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When do you need an IRS Certifying Acceptance Agent?

August 2019

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  https://www.jdsupra.com/legalnews/when-do-you-need-an-irs-certifying-16624/

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

August 2019

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 https://www.jdsupra.com/legalnews/does-it-make-sense-to-go-from-an-s-corp-45960/

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What is an Abusive Tax Trust?

August 2019

In a “legitimate” Trust, the ownership and control of the Trust assets and income is “separate” from a Settlor’s control and https://www.jdsupra.com/legalnews/what-is-an-abusive-tax-trust-56770/

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An effective compliance program can help diminish an organizational criminal fine

July 2019

On April 30, 2018, the Criminal Division of the US Department of Justice (DOJ) released a  https://www.jdsupra.com/legalnews/an-effective-compliance-program-can-13323/

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

july 2019

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: https://www.jdsupra.com/legalnews/if-you-exchange-virtual-currency-you-87129/

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Understanding how Taxpayers may Appeal to the IRS Office of Appeals

July 2019

IRS has an Office of Appeals (OOA) that operates as an “independent” organization within the IRS. The goal of the OOA is to  https://www.jdsupra.com/legalnews/understanding-how-taxpayers-may-appeal-93524/

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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

July 2019

Form 5472 is an Information Return of a 25% Foreign-Owned U.S. Corporation or a Foreign Corporation Engaged in a https://www.jdsupra.com/legalnews/penalty-of-25-000-for-foreigners-with-a-36597/

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Is There an Anti-Money Laundering (AML) Component to the Revision of the IRS EIN Process?

June 2019

An EIN is also known as a Federal Entity Tax Identification Number (EIN) and is used to  https://www.jdsupra.com/legalnews/is-there-an-anti-money-laundering-aml-92031/

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IRS can Prove that a Taxpayer Under-Reported Income

June 2019

There are Taxpayers that understate income, overstate expenses and present fraudulent claims on their https://www.jdsupra.com/legalnews/irs-can-prove-that-a-taxpayer-under-84163/

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Taxpayers can be Embarrassed when IRS Contacts a Third-Party

June 2019

Under Internal Revenue Code (IRC), Subtitle F – Income Taxes, Chapter 78 – Discovery of Liability and Enforcement of Title, Subchapter A – Examination and Inspection – Section 7602, the IRS has the authority to  https://www.jdsupra.com/legalnews/taxpayers-can-be-embarrassed-when-irs-91794/

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