What is Next after BSA turns 50?

February 2020

On 2/6/2020, the U.S. Department of the Treasury issued the 2020 National Strategy for Combating Terrorist and Other Illicit Financing (2020 Strategy).  The purpose of the 2020 Strategy is to: • Modernize the U.S. anti-money laundering/countering the financing of terrorism

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What can trigger an OFAC investigation and what can an OFAC Investigation lead to?

February 2020

OFAC investigations are often triggered as a result of: • Reports that are generated by U.S. Financial Institutions which have blocked or rejected a transaction based on a suspected sanctions violation • A self-disclosure of an OFAC apparent violation •

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FBAR Penalties: Is it per Account or per Violation?

February 2020

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: a financial interest in or signature or other authority

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Are there conflicting signals from IRS as it relates to Section 965?

February 2020

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.  The sections requires a United States shareholder to pay a transition tax on the

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Payers and Payees have Obligations to Comply with Backup Withholding

December 2019

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: • fails to provide a correct taxpayer identification number (TIN) when required,

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IRS “BEEFS UP” Section 965 COMPLIANCE for 2017 and 2018 Returns

November 2019

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 required to pay a “transition

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Indirect linkages to Tax Havens

November 2019

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 all or some of

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

November 2019

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 receive, sell,

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

October 2019

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 that those authorized may: Communicate with

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

October 2019

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 infrastructure inside the LBI.  The campaigns require strategic

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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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IRS using Data Analytics to Uncover Criminal Arrangements

August 2019

IRS-Criminal Investigation (IRS-CI) is a federal agency department specifically authorized to investigate and  https://www.jdsupra.com/legalnews/irs-using-data-analytics-to-uncover-67780/

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