The Who, What, When and Where of FBAR/FINCEN Form 114
Any taxpayer with delinquent FBARs or other tax filings should consult with a tax professional regarding the best option for resolving these issues. For any questions on this or any other tax-related matter, please feel free...
Taxpayers With Undisclosed Foreign Accounts and Activities Beware: The IRS and Other Taxing Authorities Are Coordinating Efforts to Tackle International Tax Evasion
On January 23rd the Joint Chiefs of Global Tax Enforcement (J5) released the following statement regarding its “day of action” conducted on January 22nd: A globally coordinated day of action to put a stop to the suspected...
Another Arrow in the Taxpayer’s Quiver against Trust Fund Penalties: Supervisory Approval
We all know that the IRS is quick to pull the trigger on penalties, especially trust fund penalties, which the IRS rightfully views as Uncle Sam’s money. But the Tax Court’s January 21st decision in Chadwick vs....
PLR Update: IRS Issues its “No Ruling” List for 2020 as well as Extends a Surprising Invitation for PLR Requests in a Hot Button Area
In a previous blog post linked here, I outlined the IRS private letter ruling process, including the mechanics of making a request and tips for presenting your ruling request to the IRS. In this blog post, I touch on the...