Each year taxpayers are required to disclose their participation in a reportable transaction by filing a Form 8886 with the IRS. In recent years the IRS has added both Section 831(b) micro captives and syndicated...
IRC Section 6038D requires any taxpayer who has an interest in a “specified foreign financial asset” to disclose that asset to the IRS on a Form 8938 attached to the taxpayer’s annual tax return. The penalty for failure...
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...
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...
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....
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