Foreign Trust Forms 3520 and 3520-A Penalties: A Potential Gold Mine for the IRS

The Internal Revenue Service (IRS) is looking for money.  As part of the hunt, it has instituted various “campaigns” (full list here) aimed at areas in which there is greater taxpayer noncompliance that may involve significant tax dollars and penalties. One such campaign involves the failure by a US person to file complex information-reporting tax … Continue reading Foreign Trust Forms 3520 and 3520-A Penalties: A Potential Gold Mine for the IRS

Expatriation – IRS Told to Get Tough and Enforce the Law

The Treasury Inspector General for Tax Administration (TIGTA) recently issued its report “More Enforcement and a Centralized Compliance Efforts Are Required for Expatriation Provisions”, (Reference Number: 2020-30-071, September 28,2020) telling the Internal Revenue Service (IRS) that it needs to do more to make sure that the rising number of US citizens and long term residents … Continue reading Expatriation – IRS Told to Get Tough and Enforce the Law

Section 965 Transition Tax – Enforcement & Audits Begin Next Month

By now most of my readers will have some familiarity with  Internal Revenue Code Section 965, and the “deemed repatriation” or “transition tax” introduced by the Tax Cuts and Jobs Act (“TCJA”) in 2017.  My earlier blog post provided significant detail about this new tax law provision which is intended to move the US international tax … Continue reading Section 965 Transition Tax – Enforcement & Audits Begin Next Month

IRS Wants Help on Cryptocurrency Audits – Seeks Private Crypto Gurus

We know that the Internal Revenue Service (IRS) has been investigating tax evasion and other crimes tied to cryptocurrency. The agency has been hard at work for some time in scrutinizing crypto and for the past two years, it has been in  the process of developing and executing investigation techniques to enforce cryptocurrency compliance.  Along … Continue reading IRS Wants Help on Cryptocurrency Audits – Seeks Private Crypto Gurus

IRS’ Crypto Guidance – No, You Cannot Rely On It.

Cyptocurrency (such as Bitcoin) is a type of virtual currency. This is an emerging area and consequently transactions involving use of crypto come with an enormous amount of US tax uncertainty. The Internal Revenue Service (IRS) has taken a keen interest in virtual currency since its use provides a way for taxpayers to avoid tax … Continue reading IRS’ Crypto Guidance – No, You Cannot Rely On It.

Cryptocurrency and Your 2019 Tax Return – Handle With Care

It’s been no secret that cryptocurrency is in the  crosshairs of the Internal Revenue Service (IRS).  Virtual currency is one of the IRS “campaigns” and criminal investigations related to crypto already started last year.  Taxpayers are being sent “educational” letters to remind them and warn them of their tax obligations when it comes to the … Continue reading Cryptocurrency and Your 2019 Tax Return – Handle With Care

Is the IRS Trying to Find You?

Moving is always a stressful event and it is easy for certain things to be overlooked. One item on your moving checklist that is critical to remember: properly notifying the Internal Revenue Service (IRS) of your change of address.  Today's post tells you how to do it right and the terrible things that can happen … Continue reading Is the IRS Trying to Find You?

Did you Join OVDP? You’d Better Still be in Tax Compliance!

The Internal Revenue Service (IRS) has now expanded its compliance campaigns and included “post Offshore Voluntary Disclosure Program compliance” on the list. On July 19th, the IRS through its Large Business and International (LB&I) Division announced six new “compliance campaigns” for taxpayers. Significantly, one of these campaigns targets taxpayers who had entered an Offshore Voluntary Disclosure Program (OVDP) … Continue reading Did you Join OVDP? You’d Better Still be in Tax Compliance!

Have you Expatriated or Thinking of Expatriating? IRS Now Looking Closely

On July 19th, the Internal Revenue Service (IRS) through its Large Business and International (LB&I) Division announced six new “compliance campaigns” for taxpayers. Significantly, one of these campaigns targets “expatriation”, and apparently reaches back to those who “expatriated” on or after June 17, 2008.  The campaign will be looking at “expatriates” – US citizens who … Continue reading Have you Expatriated or Thinking of Expatriating? IRS Now Looking Closely

The J5 International Tax Hunt is On….

Many countries are waking up to the fact that offshore structures, financial instruments, cryptocurrency and other advances in technology, when inappropriately used, are fast outwitting their tax collectors. This wake-up was eventually accompanied by the realization that there is more power in collaboration and in numbers. Who or What is the “J5”? The “Organization for … Continue reading The J5 International Tax Hunt is On….