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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Los Contadores Forenses son “Detectives Privados”

November 2019

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 inicio del fraude. Además, la desesperación económica, un solo evento

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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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An IRS “John Doe” Summons is a Powerful Weapon that can Puncture Attorney-Client Privilege

November 2019

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 Revenue Manual (IRM), circumstances exist when attorney client

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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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Automatic Exchange of Information leads to Deposit Drops at International Financial Centers

October 2019

On June 7, 2019, the Organisation for Economic Co-operation and Development (OECD) released a Memo which is a “summary of ongoing work to assess the impact of increasing tax transparency and exchange of information (EOI) on cross-border financial activity using

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Guilty from the Get-go in the IRS Updated Voluntary Disclosure Program?

September 2019

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 TA’s request for the

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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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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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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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Is your Passport at Risk?

May 2019

Certain US Taxpayers that have been identified by IRS with https://www.jdsupra.com/legalnews/is-your-passport-at-risk-64238/

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IRS: Offshore Financial Accounts will NOT go Unnoticed

May 2019

On March 15, 2019, IRS reported that hiding money or assets in unreported offshore accounts remains on https://www.jdsupra.com/legalnews/irs-offshore-financial-accounts-will-15248/

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