Searching Content indexed under Tax Authorities by James N. Mastracchio ordered by Published Date Descending.
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Choice Of OVDP Program- Irrevocable?
Several taxpayers sued the IRS to remove them from the OVDP program and allow them entrance into the streamline program, an alternative program open to taxpayers after July 1, 2014.
United States
1 Aug 2017
Partnership Proposed Regulations Re-Released
Today, the prior January 2017 partnership audit proposed regulations were re-released.
United States
21 Jun 2017
The Other Testimony On June 8th
While it seems the world was watching the testimony of the former FBI director yesterday, another hearing was underway.
United States
20 Jun 2017
Partnership Audit Guidance Soon?
On January 1, 2018 the new partnership audit rules become effective.
United States
15 Jun 2017
OVDP Campaign Declines And Withdrawals
In January, the IRS released a list of 13 audit campaigns designed to focus resources on areas of concern for the IRS examination teams.
United States
18 May 2017
IRS Won't Shut Down
It appears both the House and Senate will pass H.R. 244, to appropriate funds for the IRS sometime later this week.
United States
8 May 2017
The Dirty Dozen Top Concerns For 2017
With the tax filing season now open, the IRS has listed its top 12 tax scams and warned U.S. taxpayers that participation in these prohibited activities could result in civil and criminal tax exposure.
United States
2 Mar 2017
IRS Announces 13 Campaigns New Focus
The Large Business and International division of the IRS has restructured its approach to examinations. Yesterday, it released its list of 13 focus areas for issue- based examinations and concerns for compliance.
United States
10 Feb 2017
Tax Regulations On Hold-The New Regulatory Freeze
According to a memorandum issued to all agency heads, no federal agency may send regulations to the Federal Register for publishing until advised by the appropriate OMB personnel or designee.
United States
1 Feb 2017
Foreign Exchange Rates And The Exit Tax
We have seen several advantages from the increase in the U.S. dollar strength against foreign currencies when tackling the Exit Tax.
United States
12 Jan 2017
Foreign Records Exception 2nd Circuit Remands
Yesterday, the Second Circuit remanded a case involving foreign bank records for further development.
United States
10 Jan 2017
Fast Track Settlements For Collection Cases
Late last year the IRS issued guidance on Fast Track settlement procedures for collection cases.
United States
10 Jan 2017
Data Protection And The Swiss DOJ Settlement Program
The program for non-prosecution agreements for Swiss Banks is largely settled.
United States
17 Oct 2016
DOJ And IRS Expanding Offshore Enforcement Efforts: Financial Institutions And Individual Taxpayers Beware
A few months ago, we posited that the DOJ and IRS were expanding offshore enforcement efforts beyond Europe, with a likely new target of those efforts being Singapore.
United States
10 Oct 2016
Israel Cleared To Implement FATCA And Report On U.S. Persons
A recent decision by the Israeli Supreme Court has cleared the way for FATCA implementation by lifting a temporary injunction on the disclosure of information to U.S. authorities under IGA.
United States
19 Sep 2016
Taxpayers Putting Pressure On Courts to Establish The IRS's Burden Of Proof In Offshore Disclosure Cases
The case involved the appropriate burden of proof the Internal Revenue Service must meet when the IRS asserts a willful failure to file penalty for the Report of Foreign Bank and Financial Accounts.
United States
19 Sep 2016
The Streamline Program Turns Two
The (SFCP) is now two years old. The SFCP was designed for taxpayers whose failure to disclose their offshore accounts was "non-willful," due to a lack of understanding or knowledge of reporting requirements for U.S. persons.
United States
9 Aug 2016
IRS Seeks To Speed Up FATCA Reporting With Imposition Of Year End Deadline To Finalize IGAs
The Foreign Account Tax Compliance Act ("FATCA") was enacted in 2010 by Congress to target non-compliance by U.S. taxpayers using foreign accounts.
United States
9 Aug 2016
Tax Court Finds Predictive Coding Satisfies Reasonable Inquiry Standard For Responding To Discovery Requests
The IRS and Petitioners had agreed that Petitioners would run a search for terms determined by the IRS on the potentially relevant documents.
United States
28 Jul 2016
House Ways And Means Wants Probable Cause Before Seizure
The Internal Revenue Service (IRS) has come under scrutiny recently for seizing assets that the IRS claims were the subject of structuring violations.
United States
18 Jul 2016
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