By: Usman Mohammad The CPA Journal January 2019 Edition On November 20, 2018, the IRS published an Interim Guidance Memo concerning voluntary disclosures, captioned “Updated Voluntary Disclosure Practice” (http://bit.ly/2UHHdLm). The memo sets forth the IRS’s current policy for handling voluntary disclosures (both offshore and domestic) following the closing of the IRS’s
By Wilda Lin The CPA Journal October 2018 Edition Reports of Foreign Financial and Bank Accounts (FBAR) have gained prominence since the Department of Justice began investigating the accounts of Swiss banks, starting with UBS almost a decade ago. Who must file FBARs? Many people who own foreign accounts hail
By: Michael Sardar August 2018 Edition The CPA Journal On March 13, the IRS announced that it will close the Offshore Voluntary Disclosure Program (OVDP), effective September 28, 2018. In the announcement, the IRS encouraged taxpayers who need to disclose noncompliant and unreported foreign accounts and assets to come forward before
By Cassandra Vogel The CPA Journal June 2018 Edition The IRS’s streamlined filing procedures for offshore assets were announced in 2012 for non-U.S. residents and extended to U.S. residents in 2014. The streamlined procedures are open to taxpayers whose failure to report foreign financial assets “did not result from willful conduct.”
By Jerald David August Reprinted From The Winter 2018 Issue Of ALI-CLE’s The Practical Tax Lawyer Winter 2018 Edition On December 22, 2017, President Trump signed into law the Tax Cuts and Jobs Act (“TCJA”) of 2017, P.L. 115-97, which introduced a set of tax cuts and other reforms that will affect
By Wendy Abkin, George Abney, and Caroline D. Ciraolo Tax Executive Institute February 2018 TO DISCLOSE OR NOT TO DISCLOSE, THAT IS THE QUESTION Hamlet’s thoughts weighed heavily upon him. Should he suffer the slings and arrows of outrageous fortune, or take arms against a sea of troubles? For the young Prince
By Bryan C. Skarlatos & Henry Stow Lovejoy Journal of Tax Practice & Procedure October – November 2017 Edition Taxpayers in a dispute with the IRS have a choice of forum in which to litigate. The Tax Court provides a pre-payment judicial review while taxpayers who pay in advance can sue for refund
By Bryan C. Skarlatos & Henry Stow Lovejoy Journal of Tax Practice & Procedure June – July 2017 Edition Taxpayers who have underpaid their taxes can avoid accuracy-related penalties under Code Sec. 6662 by demonstrating that they acted with reasonable cause and in good faith. In general, the most important factor in determining
By Henry Stow Lovejoy Original Publication: The CPA Journal, April 2017 Edition Re-Published & Updated Publication: The Practical Tax Lawyer, Summer 2017 Edition The Internal Revenue Code (IRC) requires the filing of a number of different information returns with respect to foreign entities or transactions. These “international information returns” include Form 5471 (for
By Cassandra Vogel The CPA Journal November 2016 Edition The migration of workers into and out of the United States is a fact of the modern interconnected world. Consequently, many U.S. taxpayers acquire an interest in a foreign pension plan or other deferred compensation arrangement during time spent working abroad. Because
