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Filing Requirements Internal Revenue Service Audits

Allen Barron, Inc.

IRS Revisions to the Voluntary Disclosure Program for 2024

Allen Barron, Inc. on

What are the IRS revisions to the Voluntary Disclosure Program for 2024? The foundation of the current IRS Voluntary Disclosure Program (VDP) goes as far back as 2009 when the agency worked to provide U.S. taxpayers with a...more

Allen Barron, Inc.

The Statute of Limitations for an IRS Audit

Allen Barron, Inc. on

What is the statute of limitations for an IRS audit? What rules extend the window for an IRS audit? How long does the IRS usually have to complete an audit of your taxes? Everyone may have a little fear in the back of...more

Allen Barron, Inc.

Questions Regarding Offshore Accounts and FBAR Filing Requirements

Allen Barron, Inc. on

Many US taxpayers still have questions regarding offshore accounts and FBAR filing requirements and compliance. Is there a genuine risk their activities (or lack of compliance) will come to light? The definition of a US...more

Skadden, Arps, Slate, Meagher & Flom LLP

Tax Enforcement: A Spotlight on Complex Partnership Structures

The boost in funding for the Internal Revenue Service (IRS) provided in the Inflation Reduction Act of 2022 (IRA) comes just as it has started rolling out in earnest programs focusing on auditing complex partnership...more

Holland & Knight LLP

TIGTA Tasks IRS with Enhanced Enforcement of Noncompliant Expatriates

Holland & Knight LLP on

The U.S. Treasury Inspector General for Tax Administration (TIGTA) recently audited the Internal Revenue Service's (IRS) programs to ensure compliance by expatriates with the provisions under Sections 877 and 877A of the...more

Foodman CPAs & Advisors

How does IRS Identify Cases with Audit Potential?

Understanding how the IRS identifies cases that have audit potential can be learned from the CONGRESS OF THE UNITED STATES (CONGRESSIONAL BUDGET OFFICE) Report released on July, 2020: Trends in the Internal Revenue Service’s...more

Foodman CPAs & Advisors

What if the IRS wants to “Audit” your Tax Returns?

The IRS might want to audit (also known as a review or an examination) an Individual Taxpayer’s accounts and financial information to verify that the information that the Individual Taxpayer is reporting is compliant with the...more

Fisher Phillips

When Should Health Plan Sponsors Prepare For The Revised 5500? Right Now!

Fisher Phillips on

In July 2016, the U.S. Department of Labor (USDOL), the Internal Revenue Service, and the Pension Benefit Guaranty Corporation released proposed revisions to the Form 5500 Annual Return required for certain ERISA-covered...more

Dickinson Wright

Inter-Company Pricing Practices of Taxpayers with Foreign Affiliates

Dickinson Wright on

The Internal Revenue Service has increased its scrutiny of inter-company pricing practices of taxpayers with foreign affiliates and has provided agents conducting audits with standard language requesting information about...more

Orrick, Herrington & Sutcliffe LLP

Audits of Multifamily Housing Bonds Triggered by Failure to File Form 8703

IRC Section 142(d) requires operators of qualified residential rental properties to file Form 8703, Annual Certification of a Residential Rental Project annually. A number of recent audits of multifamily housing bonds appear...more

Troutman Pepper

Tax Update, Volume 2017, Issue 2

Troutman Pepper on

THE NEW REGULATIONS EXPAND THE FILING REQUIREMENTS FOR FORM 5472 TO INCLUDE DISREGARDED ENTITIES WITH FOREIGN OWNERS WHEN THERE ARE CERTAIN REPORTABLE TRANSACTIONS. If a non-U.S. person (individual or corporation)...more

Orrick, Herrington & Sutcliffe LLP

IRS Updates Golden Parachute Audit Guide

This is our first of many alerts during 2017 as the new administration signals the rollback of many regulations (e.g., fiduciary rules and pay ratio). We will keep you posted. In January 2017, the Internal Revenue...more

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