Penalty Relief for Delinquent FBARs and Forms 5471 Ends August 31

Article:  The IRS has provided penalty relief in guidance related to its latest offshore voluntary disclosure initiative. The focus of this item is on who qualifies for penalty relief and procedures for obtaining this relief.
Published on June 30, 2011

Delinquent U.S. Foreign Information Returns Is Filing Under the 2011 OVDI Appropriate

Article:  This item explains the process by which taxpayers may take advantage of an opportunity to avoid a substantial portion of the penalties that would otherwise be due on previously unreported offshore accounts, entities, and income.
Published on January 13, 2012

FBAR Penalties Reduced for Six Months

Article:  The IRS has provided a framework for voluntary disclosure requests containing offshore issues, such as previously undisclosed foreign financial accounts and entities.
Published on January 28, 2011

New Foreign Trust Tax Form Project 1041NR

Article:  IRS representatives recently approved a joint project with the AICPA Foreign Trust Task Force. Together they will design a new Form 1041NR, U.S. Income Tax Return for Foreign Estates and Trusts, which tax return preparers and IRS personnel will find easier to understand, prepare, and process.
Published on May 10, 2010

IRS Provides Guidance on Return Preparer Penalties

Article:  The IRS has provided guidance (Notice 2008-46) on the implementation of the  return preparer penalties under Sec. 6694.
Published on May 12, 2010

New Reporting for Specified Foreign Financial Assets

Article:  Effective for tax years starting after March 18, 2010, new Sec. 6038D requires individual taxpayers to report any interest in “specified foreign financial assets” if the value of these assets in aggregate exceeds an applicable threshold amount.
Published on August 24, 2012

IRS Releases Procedures Allowing Appeals Review of International Penalties Prior to Payment

Article:  The IRS has made it a priority to improve voluntary compliance with the international tax provisions and to reduce the tax gap attributable to international transactions. This focus on international compliance has led to increased enforcement of international information-reporting requirements and the associated penalties.
Published on January 28, 2011

New Foreign Asset Reporting Rules

Article:  Practitioners need to be aware of the new requirements for reporting foreign assets and income and confirm that clients are complying.
Published on August 31, 2012

Advising Nonresidents and Recent U.S. Residents on Estate Tax Issues

Article:  Understanding the intricacies of residency and domicile is necessary to understand what will be included in a decedent’s estate for U.S. estate tax purposes.
Published on November 14, 2012

Focus on Tax Avoidance Leads to Changes in Foreign Reporting Requirements

Article:  The use of information reporting to prevent tax avoidance has been a major focus of the current administration and the IRS.
Published on September 01, 2010

FATCA Adds Layer of Complexity, Penalty Exposure to Offshore Asset Reporting

Article:  This item highlights the provisions of FATCA that are most likely to affect U.S. tax practitioners and their clients—the taxpayer reporting provisions of new Sec. 6038D.
Published on March 18, 2013

Significant Recent Developments in Estate Planning (Part II)

Article:  This article covers gift tax, generation-skipping transfer (GST) tax, trust developments, and the annual inflation adjustments for 2011 relevant to estate and gift tax.
Published on April 17, 2012

New Procedures Permitting Prepayment Review of International Information Reporting Penalties

Article:  The authors review the recently published new Internal Revenue Manual (IRM) Section 8.11.5, which permits taxpayers that have been assessed certain international information reporting penalties to elect prepayment review of those penalties by IRS Appeals.
Published on February 01, 2011

Scope of Foreign Trust Provisions in the HIRE Act

Article:  This article analyzes the foreign trust provisions of the HIRE Act and offers some practical guidance for practitioners to consider in their development of best practice procedures.
Published on January 28, 2011