When I served as Commissioner of Internal Revenue from 2003 through 2007, the two fears that kept me up at night were of a botched…
On November 20, 2018, the IRS published an Interim Guidance Memo concerning voluntary disclosures, captioned “Updated Voluntary Disclosure Practice” (http://bit.ly/2UHHdLm). The memo sets forth the…
Tax & Accounting Update is provided by Thomson Reuters and based on material published on Checkpoint, its online news and research platform. The Update is…
The IRS Whistleblower Regulations
A Hindrance to Tax Enforcement
In modernizing the tax whistleblower statute over the last 12 years, Congress has finally created a simple and enforceable entitlement to substantial compensation for tax…
Tax & Accounting Update is provided by Thomson Reuters and based on material published on Checkpoint, its online news and research platform. The Update is…
Passport Revocation and Denial for Seriously Delinquent Tax Debts
New IRS Procedures Signal More Stringent Enforcement
In January 2018, the IRS published procedures to begin enforcement of Internal Revenue Code (IRC) section 7345, which requires the State Department to deny the…
Tax & Accounting Update is provided by Thomson Reuters and based on material published on Checkpoint, its online news and research platform. The Update is…
The IRS's streamlined filing procedures for offshore assets were announced in 2012 for non-U.S. residents and extended to U.S. residents in 2014. The streamlined procedures…
Tax & Accounting Update is provided by Thomson Reuters and based on material published on Checkpoint, its online news and research platform. The Update is…
There was much speculation surrounding the fate of the federal estate tax leading up to the ultimate passage of the Tax Cuts and Job Act…
Reporting Virtual Currency Transactions to the IRS
Time May Be Running Out for Affected Taxpayers
IRS Notice 2014-21, issued on March 25, 2014, made it clear that the IRS would treat virtual currencies that can be converted into traditional currency…
Tax & Accounting Update is provided by Thomson Reuters and based on material published on Checkpoint, its online news and research platform. The Update is…
Written Supervisory Approval of IRS Penalties
When Must It Be Given, and Who May Give It?
The Internal Revenue Code (IRC) imposes penalties on understatements of tax as a way to encourage voluntary compliance and deter noncompliant behavior. Generally, the revenue…
Tax & Accounting Update is provided by Thomson Reuters and based on material published on Checkpoint, its online news and research platform. The Update is…
IRS Offers in Compromise
A Case Study
In situations where a taxpayer has a greater tax liability than funds, there are several options available. The taxpayer can, of course, borrow the money…
Gift Horse or Trojan Horse?
Helping Beneficiaries Avoid Hidden Tax Liens
It is the worst-case scenario for many individual taxpayers: a lien on their property. While a lien is not the same as seizure, as the…
Under Internal Revenue Code (IRC) section 6672(a), an individual can be held personally liable for a penalty for the willful failure to collect, account for,…
In 1927, the Commissioner of Internal Revenue established a Special Advisory Committee that was intended to serve as a forum to facilitate settlement of cases…
Digital Currency: Market Value of Bitcoin, Ethereum, and Litecoin
Taxation, Enforcement, and the John Doe Summons
Several years ago, the IRS started its successful takedown of secret Swiss banking with the use of a John Doe summons. Currently, it is trying…
Sifting through the Internet to find the answer to a specific question can be a daunting task. This article compiles some of the most useful…
Many individuals desire to make charitable bequests but are not certain how to do so or how they work. This is an area where a…
If it is not already on the schedule, CPAs should remember to talk to business clients about withholding on payments to nonresident aliens. A withholding…
TPP | Avoiding the Worst-Case Scenario
The IRS’s Domestic Voluntary Disclosure Practice
Most CPAs are by now familiar with the IRS's heavily publicized Offshore Voluntary Disclosure Program (OVDP), which allows taxpayers with previously undeclared foreign assets to…
OVDP and the IRS’s New Streamlined Filing Procedures
Look Before You Leap
The IRS's Offshore Voluntary Disclosure Program (OVDP) is designed to assist U.S. taxpayers who have failed to properly report or pay income taxes on offshore…
Tax & Accounting Update is provided by Thomson Reuters and based on material published on Checkpoint, its online news and research platform. The Update is…
On December 4, 2015, President Obama signed the Fixing America's Surface Transportation Act (FAST). Section 32101 of FAST adds section 7345 to the Internal Revenue…
IRS Schedule UTP and the Legal Privileges of Tax Accrual Workpapers
Understanding the Risks for Auditors
The implementation of the Schedule UTP contributes perhaps the most significant increase in tax reporting in recent memory and will greatly affect the Service's audits…