Bitcoin Is Drawing the Interest of Investors and the IRS... [ read ]
In a prior blog post (here) my colleague Chris Weeg discussed using Bitcoin as part of year end charitable giving. Bitcoin has been in the news lately as the value of a single Bitcoin has risen dramatically in the last month. Some financial experts view Bitcoin as the next great investment, while other financial investors believe that Bitcoin is a scam. Currently Bitcoin has limited usage beyond investment, but one of the Big 4 accounting firms says it has begun accepting Bitcoin as payment (here). In addition, futures trading on Bitcoin is expected to start next week.
As Year-End Approaches, Donations of Bitcoin and Other Virtual Currencies Explained... [ read ]
Time is running out to make charitable contributions for the 2017 tax year. With virtual currencies trading at record highs, contributions of this pioneering property may be a viable option for some. The most common (and valuable) virtual currency is Bitcoin, which is valued at approximately $9,600 as of this writing and up over 900% year-to-date. Other popular virtual currencies include Etherum (valued at approximately $415) and Bitcoin Cash, a split-off of Bitcoin (valued at $1,260). For those riding the Bitcoin rocket ship (or, perhaps, the Bitcoin roller coaster), you may consider taking advantage of the following favorable charitable contribution tax rules.
Buckle Your Seat Belts – Major Changes to International Taxation Currently Pending in Congress.... [ read ]
As of the date of this article, the U.S. Congress is considering two different legislative proposals that would cause significant changes to the U.S. income taxation of international business activities and investments. The U.S. House of Representatives passed on November 16, 2017, H.R. 1, the "Tax Cuts and Jobs Act" (the "House Proposal") while the Senate Finance Committee passed, on that same date, its own proposal (the "Senate Proposal"). The Senate and House proposals are generally consistent regarding the nature of the changes that would be made to the U.S. income tax laws affecting international transactions, but there are subtle differences that will need to be resolved as the legislative process moves forward to achieve passage of final legislation. This article does not attempt to summarize every change to the U.S. international tax laws that would result under the pending House and Senate proposals. Rather, this article summarizes five categories of international tax reforms under the pending proposals that would be broadly applicable and thus are important to monitor as the legislative process advances. In addition, this article does not discuss every nuance or detail relating to the pending proposals discussed herein. Instead, this article is intended to provide a high level overview of the pending proposals so that readers will be alerted and can look further into the proposals potentially impacting them.
IRS Issuing "Soft Letters" to Taxpayers Suspected of Under-Reporting their Offshore Activities... [ read ]
IRS officials are making it known that the IRS is losing patience with taxpayers who have not come forward to fully report their offshore activities. Not only is the IRS doubling down on its efforts to audit taxpayers who withdrew or were denied entry into the IRS' Offshore Voluntary Disclosure Program, the IRS recently announced a program whereby they will be sending not-so-subtle "soft" letters to taxpayers encouraging them to disclose (or else).
IRS Announces 11 New Enforcement Campaigns: Swiss Account Holders Beware... [ read ]
On November 3rd, the IRS announced the rollout of 11 Large Business and International (LB&I) enforcement campaigns. The 11 new campaigns are in addition to the 13 LB&I enforcement campaigns introduced by the IRS in January 2017
Doing More with Less: IRS CI Establishes New Investigation Units and Announces Focus on Digital Currency... [ read ]
Statistics show that IRS Criminal Enforcement is down. But it is certainly not out. Seemingly adopting the mantra "quality not quantity," earlier this year the IRS Criminal Investigations division announced the creation of two new nationally-coordinated investigation units that, according to statements made this week, the IRS expects will be fully operational in January 2018.
Weathering the Storm: 18 Tips for Assessing Your Client's Section 831(b) Micro-Captive Insurance Planning Following the Avrahami Decision... [ read ]
The Tax Court's decision in Avrahami v. Commissioner created a storm that is brewing in the I.R.C. Section 831(b) micro-captive insurance industry. Some microcaptives are a safe distance away from the storm's path. Others are at risk for an indirect hit. Still others are likely facing the very eye of the storm. The key is preparation, and this requires an objective assessment. We must know where the captive insurance planning sits on the storm's projected path so we can help our clients make the planning storm-ready. As we begin to look more closely at our clients' captive insurance planning in light of Avrahami, we should be mindful of the following warning signs:
"Qualifying" Your Settlement Offer: How to Get the IRS to Think Twice Before Rejecting a Fair Offer... [ read ]
With funding and staffing low, and caseloads high, you would expect the IRS to be more attentive in its efforts to resolve cases. But in my experience the opposite holds true, with IRS personnel seemingly more interested in moving a case to someone else's desk rather than out the door. So how do you get the IRS to seriously consider an otherwise fair settlement offer? Make it a qualified offer.
Options for Taxpayers With Unfiled Tax Returns... [ read ]
Whether due to oversight or intentional conduct, there are number of individuals and businesses with unfiled federal tax returns. Under the Internal Revenue Code (IRC) the failure to file a tax return is a misdemeanor (IRC Section 7203) punishable by imprisonment of not more than one year and a fine of up to $25,000.
Treasury and IRS to Withdraw Controversial 2704 Proposed Regulations... [ read ]
The long, tumultuous road of the proposed regulations under I.R.C. Section 2704 (the "2704 Proposed Regulations") should be coming to an end with Treasury's recent report in response to Executive Order 13789.
