The Internal Revenue Service (IRS) Voluntary Disclosure Practice (VDP) is alive and well. Its parameters are set out in Internal Revenue Manual (IRM) provisions dedicated strictly to the VDP. IRM 220.127.116.11.1 Voluntary Disclosure Practice, is available here. Under the VDP, the nature and extent of penalties to be assessed against a taxpayer will, to a … Continue reading IRS Voluntary Disclosure Practice and Closing Agreement: Understanding the Basics
Today’s post involving the case of Jonathan Zuhovitzky presents some important takeaways: The IRS can get very aggressive when it comes to assessing “willful” FBAR penalties. We see this trend is on the rise. A diligent representative, however, can get the IRS to settle an FBAR matter that is favorable to the taxpayer. It takes … Continue reading Taxpayer’s FBAR WIN: “Willful” Penalty over $9.8 Million for Mere Signature Authority — Removed Entirely
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.
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
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!
Most of my readers are aware of the “attorney-client privilege”. Generally speaking, the privilege preserves the confidentiality of communications between a lawyer and her clients. When the privilege is in place, attorneys may not divulge their clients’ secrets and cannot be "forced" to divulge them (for example, in a court proceeding or to the Internal … Continue reading Attorney-Client Privilege & John Doe: Your Secret Is Safe … But Your Identity Isn’t!