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Federal Tax Updates Archive

Will the IRS Get What It Needs?

TweetShareSharePin0 Shares President Biden proposes a $1.2 billion IRS budget hike. The first tranche of President Biden’s proposed fiscal year 2022 budget includes $13.2 billion for the IRS, a 10.4 percent increase from this year.  Biden wants the money to increase audits on wealthy individuals and corporations as well as “ new and improved online

$300bn in new tax revenues? Weighing the US intervention in global tax reform

TweetShareSharePin0 Shares The Biden administration has continued its charge to drive through international corporate tax reforms. Yesterday we evaluated Treasury Secretary Yellen’s call for an end to the race to the bottom. At the same time, the Biden administration released its ‘Made in America tax plan’, and the headlines of its international proposals were more

Deferred Prosecution Agreements (DPA) & Voluntary Disclosure

TweetShareSharePin0 Shares Deferred Prosecution Agreement (DPA) Deferred Prosecution Agreement (DPA) Deferred Prosecution Agreements (DPA): Sometimes when the US government uncovers a potential fraud, they still require additional information and help from inside the organization or group subject to the investigation in order to get a better grasp on what’s going on — and to build

It’s time to end the race to the bottom on corporate tax

TweetShareSharePin0 Shares Sometimes things move slowly – and then they go very fast indeed. “[A] consequence of an interconnected world has been a thirty-year race to the bottom on corporate tax rates. Competitiveness is about more than how U.S.-headquartered companies fare against other companies in global merger and acquisition bids. It is about making sure

US Citizens Living Abroad & Tax: What does IRS Require?

TweetShareSharePin0 Shares US Citizens Living Abroad US Citizens Living Abroad US Citizens Living Abroad: When a U.S. Person resides overseas in a foreign country, they are still subject to US tax on their worldwide income. This is different than when a person actually expatriates from the United States. If a person actually expatriates, then they

Court of Federal Claims Confirms Lower Willful FBAR Standard

TweetShareSharePin0 Shares Court of Federal Claims Confirms Lower Willful FBAR Standard: FBAR Reckless Disregard & Willful Penalty Ruling  (US v Kimble) FBAR Ruling on Willfulness and Reckless Disregard: While many Courts such as Kaufman, Girlaldi, and Boyd have ruled in favor of US Person Taxpayers in non-willful FBAR Penalty cases (These Courts all limited FBAR Violation Penalties

CA 9th  Circuit Appeals Caps Non-Willful FBAR Penalty to $10K

TweetShareSharePin0 Shares CA 9th Circuit Appeals Caps Non-Willful FBAR Penalty to $10K CA 9th  Circuit Appeals Limits Non-Willful FBAR Penalty to $10K Ninth Circuit Limits Non-Willful FBAR Penalty to $10K: In welcome news for US Taxpayers with unreported foreign accounts and FBAR Penalties who find themselves in Federal Court facing off against the US Government in

Connecticut Court Limits Non-Willful FBAR Penalty Per Form

TweetShareSharePin0 Shares Connecticut Court Limits Non-Willful FBAR Assessment Penalty Per Form Connecticut Court Limits Non-Willful FBAR Assessment Penalties Connecticut Court Limits Non-Willful FBAR Assessment Penalty Per Form: In United States v. Zvi Kaufman No. 3:18-cv-00787, the U.S. Government sought to enforce IRS non-willful FBAR penalties against the taxpayer for several years of noncompliance. There was

Virginia Homeowner Charged in Declaring Fraudulent Streamlined (New)

TweetShareSharePin0 Shares Willful Streamlined Treatment Brings About Wrongdoer Charge False Streamlined Offshore Declaring Brings About Criminal Tax Obligation Costs False Streamlined Offshore Declaring Brings About Criminal Tax Obligation Costs ( USA of America v. Azizur Rahma n): To help Taxpayers with entering into conformity for not correctly revealing international accounts in previous tax obligation years–
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