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By on February 28, 2023
When a taxpayer omits a foreign account from an FBAR form and that omission is nonwillful, federal law can still impose a steep monetary penalty. Originally that penalty was capped at $10,000, but the law requires that the maximum penalty be inflation-adjusted each year. Currently, the maximum nonwillful penalty is $15,611.
The IRS Gets Serious About ERC Abuse
By on February 21, 2023
In a prior blog post, I discussed how both the IRS Examination Division and the IRS Criminal Investigation Division were starting to focus on Employee Retention Credits (ERC) and ERC promoters. In a recent interview, an IRS CID official said that there have already been 10 or 11 ERC indictments.
Can BBA Partners Make Deposits Under IRC Section 6603?
By on February 10, 2023
If you owe the IRS money in 2023, the interest accruals are far more costly than they have been in recent history. That is because Congress requires the IRS to charge a mark-up on the federal short-term rate, which has skyrocketed. Congress also has mandated that interest be compounded daily. Under these rules, most taxpayers are currently facing a 7% interest rate that compounds daily. Given these staggering interest rates, more and more of my clients are considering making what is known as a "deposit" to the IRS. Deposits stop interest from accruing to the extent of the amount of the deposit.
IRS Proposes A New Acronym and a New Tip Reporting Program
By on February 9 2023
The government loves a good acronym for a program, institution or act, like FATCA (Foreign Account Tax Compliance Act), TEFRA (Tax Equality and Fiscal Responsibility Act), NASA or IRS. There must be a branch of the government solely dedicated to creating acronyms and making sure the acronym is not offensive, like Seattle's South Lake Union Trolley which I understand was quickly changed to South Lake Union Streetcar.
What Do The National Taxpayer Advocate and David Letterman Have In Common?
By on February 7, 2023
When I was in college, Late Night With David Letterman, which was on NBC immediately after The Tonight Show With Johnny Carson, was must see TV. I know I am dating myself, but almost every weeknight my fraternity brothers and I would watch Late Night to see Dave, Paul Schafer, Larry "Bud" Melman, stupid pet tricks, stupid people tricks, the guy under the seats and other wacky bits. Of course, this was only after we had completed 2-3 hours of quality study time at the fraternity house. I know from recent experience that you can waste a whole weekend watching old Late Night clips on YouTube, including an audience favorite, the nightly Top 10 list. The Top 10 list was usually topical, but could be anything.