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Tax Planning Internal Revenue Service Enforcement Actions

Gray Reed

Travel Alert: How IRS Debt Can Affect Your Passport

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By law, the IRS certifies taxpayers with “seriously delinquent” tax debts to the Department of State affecting passport status and renewal when certain conditions or thresholds are met. The IRS will send a Notice called a...more

Gray Reed

The IRS is Hiring an Army to Audit Corporations, Partnerships, and High-Income Individuals

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The IRS has been understaffed for many years, and this has led to a decline in the number of audits conducted.  The personnel shortage has also made it difficult to keep up with the growing complexity of the tax code and to...more

Polsinelli

Conservation Easements: Palpable Fraud or Honest Mistakes? A Federal Jury Returns a Split Verdict

Polsinelli on

On September 22, 2023 a federal jury convicted two promoters, CPA Jack Fisher and attorney James Sinnott, in the Department of Justice’s (“DOJ”) first criminal trial over allegedly abusive syndicated conservation easements...more

Polsinelli

Beware, the IRS is Coming: More IRS Audits to Focus on High-Net Worth Individuals and Passthrough Entities

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After much anticipation, the IRS has finally announced a strategic operating plan to spend the nearly $80 billion in funds that it was allocated through the Inflation Reduction Act. Since this bill was signed, the new IRS...more

Freeman Law

Section 6751(b) Penalty Approval Circuit Split

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Eleventh Circuit Sides with Ninth Circuit on Section 6751(b) Circuit Split - Introduction: Section 6751(b) and the Timing of Supervisory Approval of a Penalty - The Eleventh Circuit’s decision in Kroner v. Commissioner,...more

Gray Reed

Non-Willful FBAR Penalties Will be Much Higher in the Fifth Circuit

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On November 30, 2021, the Fifth Circuit parted ways with the taxpayer friendly decision of the Ninth Circuit that non-willful penalties are capped at $10,000 per FBAR filing instead of the $10,000 per unreported bank account...more

Foodman CPAs & Advisors

What To Do If The IRS Wants to Audit You

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Rule #1: Don’t Panic! Under the Biden Administration’s proposed American Families Tax Plan, there is the possibility of more tax audits, but only for a certain groups of high income people. That’s because more information...more

Gray Reed

A Guide to Office Audits with the IRS

Gray Reed on

When a tax return has been selected for office examination, generally the examination of the return will be conducted at the office of the IRS.  Normally a taxpayer will find an office examination has begun when he or she has...more

Freeman Law

[Webinar] Updates: IRS Tax Enforcement, Taxation of Settlements, and Cross-Border Tax Planning - August 31st, 3:00 pm CT

Freeman Law on

Join us as we discuss important developments and bring you up to speed on current initiatives. Many businesses are still facing unprecedented challenges, and we are here to provide insights. During this information-filled...more

Gray Reed

The Basics of the IRS and Tax Audits

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There is a general misconception about what the IRS can and cannot do.  Owing money to the IRS is not like owing any other creditor.  The IRS is one of only a few creditors who can seize and sell your home even though state...more

Burr & Forman

Summary of Proposed 2021 Federal Tax Law Changes

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President Biden has proposed major changes to the Federal tax laws, some of which are sought to be effective earlier in 2021 (i.e., we are already operating under these changes, if they later become adopted), as compared to...more

Gerald Nowotny - Law Office of Gerald R....

Taxing Times - April 2021

Male Escort Gets 21 Months In Prison For Tax Case - He lied on his tax returns, resulting in a tax loss to the IRS of $278,325. A male escort who lied to the IRS about his income was sentenced to 21 months in prison and...more

Foster Garvey PC

The IRS Will Put the American People First — No, Really (But Only for a Limited Time)

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Wednesday, March 25th, in the wake of the recent decision by the Internal Revenue Service (“IRS”) to extend the income tax filing and payment deadlines to July 15, 2020, it announced a new taxpayer-friendly program called the...more

Foodman CPAs & Advisors

Banquero Irá a la Cárcel por FATCA

El 11 de Noviembre del 2018, el Departamento de Justicia de los EE. UU. (“DOJ”) informó que el banquero Adrian Baron, el ex Director de Negocios y ex Director Ejecutivo de Loyal Bank Ltd, un banco “off-shore” con oficinas en...more

Foodman CPAs & Advisors

Banker will go to jail over FATCA

On September 11, 2018, the US Department of Justice (DOJ) reported that banker Adrian Baron, the former Chief Business Officer and former Chief Executive Officer of Loyal Bank Ltd, an off-shore bank with offices in Budapest,...more

Foodman CPAs & Advisors

El IRS está pendiente al Cripto

El Jefe de Investigación Criminal del IRS, Don Fort, declaró recientemente: "Es posible utilizar Bitcoin y otras Criptomonedas de la misma manera que las cuentas bancarias extranjeras para facilitar la evasión de impuestos"....more

Foodman CPAs & Advisors

IRS issues a “Tax Book”

During 2017, 245 million tax returns were processed by the IRS and more than $3.4 trillion in federal taxes was paid by individuals and businesses to the US Treasury. ...more

Foodman CPAs & Advisors

La habilidad del IRS de negar o revocar los Pasaportes de los Contribuyentes con deudas fiscales significativas es uno de los...

El Departamento de Estado de los EE.UU esta requerido a denegar la solicitud de pasaporte de un individuo y está autorizado a revocar o limitar un pasaporte existente si el IRS certifica que el individuo tiene una deuda...more

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