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.
TIGTA Report on IRS Estate and Gift Tax Examinations... [ read ]
On September 28th, the Treasury Inspector General of Tax Administration (TIGTA) issued a report recommending changes to fix the procedures the IRS uses to select estate and gift tax returns for examination.
IRS Extends Hurricane Tax Relief to Dallas and Tarrant Counties... [ read ]
Hurricane Harvey tax relief has been extended to taxpayers residing in Dallas and Tarrant counties.
