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Court Upholds FBAR Penalties, but Rejects Government's Assessed Interest and Late Charges
By on July 28, 2015
In Moore v. U.S., No. C13-2063 (W.D. Wash. July 24, 2015), Judge Richard Jones examined a case in which FBAR penalties of $10,000 were assessed for each year from 2005 through 2008. The Court held the IRS's decision to assess the FBAR penalties was not arbitrary, capricious or an abuse of discretion.
A Look Back at More than a Century: The Federal Income Tax
By on July 28, 2015
Every April, millions of Americans brave the spring ritual of filing an income tax return. In the rush to complete their returns (and, if they are lucky, claim a refund), most give little thought to the fascinating origin and history of the tax that will celebrate its 102nd birthday this October. Our modern federal income tax represents a defining marker in our nation's history and character, with foundational - and, some might say, uniquely American - economic theory. A tax with Civil War origins, it played a key role in the course of American class politics, evolving from a limited-scope "class tax" to the "mass tax" that became the backbone of our federal system.
This article was originally published in Today's CPA, July/August 2015 (a publication of the Texas Society of CPAs).No Fifth Amendment Protection for Foreign Account Records, Government Prevails in the Third Circuit
By on July 20, 2015
On July 17th, a panel for the U.S. Court of Appeals for the Third Circuit held there is no Fifth Amendment protection for foreign bank account records. U.S. v. Chabot, No. 14-4465 (3d Cir. July 17, 2015).
Offshore Voluntary Disclosures: The IRS Continues to Add New Foreign Banks to the "Bad" Bank List
By on July 14, 2015
The IRS continues to add to its list of "bad" banks, having added eight banks since June and counting. Taxpayers with undisclosed accounts at foreign banks on the list face a heightened 50-percent penalty under the IRS's Offshore Voluntary Disclosure Program.
Combating the Growing Problem of Tax Fraud and Identity Theft
By on July 13, 2015
Identity theft in which a taxpayer's name and tax identification number are stolen and used in order to obtain fraudulent refunds continues to be a growing problem for the IRS and the victim taxpayers.
By on July 13, 2015
The IRS may be close to issuing new regulations on valuation that could significantly increase transfer tax costs. As a result, it is prudent for families who are contemplating gifts of family entity and limited partnership interests to make the gifts now, while the valuation discounts are still available.
The U.S. Department of Labor's Proposed Fiduciary Standard Rule
By on July 10, 2015
The U.S. Department of Labor is considering a rule under the Employee Retirement Income Security Act of 1974 (ERISA) that would, in a nutshell, assign "fiduciary status" to those who provide financial advice about employee retirement – for example advice about your 401(k) account.
The IRS Voluntary Disclosure Program
By on July 7, 2015
The federal tax system is a voluntary system that relies on taxpayers to file complete and accurate tax returns. However, the IRS released a study reporting that individuals and businesses underpay their taxes by an estimated 17% each year, resulting in almost $450 billion of lost tax revenues each year.
By on July 2, 2015
In the first judicial decision on investor control in thirty years, the IRS scores a landmark victory that poses a material threat to owners of variable life insurance policies and the perceived tax deferral benefits of such policies.