The IRS announced that effective Oct. 1, 2016, it will rarely conduct Appeals Conferences in person. More specifically, Internal Revenue Manual (IRM) 220.127.116.11, blandly entitled “Conference Practices,” provides that ALL conferences will be held by telephone except under certain specific enumerated circumstances.
Archive for Ronald Marini
On July 25, 2016, we posted Tax Havens Coming Clean and Becoming Transparent where we discussed that the Inland Revenue Authority of Singapore has issued an e-Tax Guide on the territory’s general anti-avoidance rule in Section 33 of the Income Tax Act. The guide, issued on July 11, 2016, explains the three tests to determine whether the GAAR should apply.
An Israeli Supreme Court panel has thrown out a challenge to a tax information-sharing agreement with the U.S. and removed a temporary block on FATCA’s implementation, rejecting arguments that the agreement violates the rights of Israelis.
The U.S. Department of the Treasury revealed on September 15, 2016 that it is drafting rules to curb U.S. Multinationals from obtaining U.S. foreign tax credits as a result of foreign government’s audits resulting in foreign tax adjustments for U.S. Multinationals.
In Chief Counsel Advice 201637012, released September 9, the IRS has determined that whether a taxpayer qualifies for abatement of failure to timely file and pay penalties turns on whether the delinquencies were caused by her mental incapacity.
We previously posted “Is This the End of Discounting Transfer Taxes with LLC’s and FLPs?” where we discussed that the Internal Revenue Service issued a proposed regulation which would beef up IRC Section 2704 of 1986 to preclude many of the presently available discounting techniques. In addition, this proposed regulation would expand the purview of section 2704 to include not only partnerships and corporations but LLCs, S corporations, and other family “business” transfer entities.
According to Law360, a certified class of more than a million tax preparers ranging from accountants to attorneys urged a D.C. federal judge Wednesday to block the Internal Revenue Service from charging a fee for issuing a preparer tax identification number, arguing the fee is unlawful.
So here I am just another 59-year-old tax attorney who is sure that technology has it out for him, sitting in my office trying to get a few more cases moving forward while I wait for the Labor Day weekend, and I’m trying to fax (267) 941-1115 (the OVDP preclearance number) a preclearance for yet another client who wants to enter the OVDP program.
Naturally, I’m waiting for my E-Fax confirmation that this request for preclearance has gone through to the IRS and today I received not 1 but 2 messages that my E-Fax, that I rely on for communicating with the IRS, was not able to deliver either of my faxed requests.
With the implementation of FATCA, the ongoing efforts of the IRS and the Department of Justice to ensure compliance by those with U.S. tax obligations have raised awareness of U.S. tax and information reporting obligations with respect to non-U.S. investments.
The Internal Revenue Service today warned tax professionals of a new wave of attacks that allow identity thieves to file fraudulent tax returns by remotely taking over practitioners’ computers.
As part of the Security Summit effort, the IRS urged tax professionals to review their tax preparation software settings and immediately enact all security measures, especially those settings that require usernames and passwords to access the products. The IRS is aware of approximately two dozen cases where tax professionals have been victimized in recent days.
We previously posted on June 25, 2016 Federal Agents & Prosecutors Gearing Up to Utilize “Panama Papers” in Their Prosecutions where we discussed that Federal agents and prosecutors are “chomping at the bit” to exploit the Panama Papers and launch prosecutions, a senior federal law enforcement official told NBC News, but want to be sure that the way the huge data dump about offshore money was obtained doesn’t jeopardize their cases.
On September 30, 2015, we posted Judge Denies Injunctive Relief for FATCA Implementation!, where we discussed that an Ohio federal judge said that Senator Rand Paul, R-Ky., and others do not have standing in a challenge to the offshore financial account tax enforcement measures enacted in the Foreign Account Tax Compliance Act and they were not likely to succeed on the merits in the case. The case is Crawford v. U.S. Dep’t of Treasury, S.D. Ohio, No. 3:15-cv-00250, 9/29/15.