To avoid harsh penalties, a taxpayer should timely file all foreign information returns, even if that taxpayer cannot timely file its income tax return.
A pattern of fraudulent conduct in a tax accountant’s preparation of his clients’ returns was not sufficient to prove that underpayments on his own returns were due to fraud.
This item outlines the pros and cons of the various types of installment agreements.
The IRS issued final rules for the penalty imposed on material advisers for failing to provide the IRS a list of advisees with respect to reportable transactions.
Congress passed the Trade Facilitation and Trade Enforcement Act of 2015, making permanent the moratorium on states and localities taxing Internet access.
The IRS issued final rules on how to apply the $10,000-per-day penalty under Sec. 6708 when a material adviser fails to provide the Service a list of advisees with respect to reportable transactions.
This item discusses the PATH legislation’s immediate impact on certain federal penalty computations.
The Tax Court held that a notice of determination from a collection due process hearing is valid for purposes of starting the period in which a taxpayer must file a petition with the Tax Court if the notice is actually received by the taxpayer.
Qualifying taxpayers who failed to report foreign-source income and can prove their conduct was not "willful" could enjoy significantly reduced penalties.
IRS could impose penalty because the examiner had made an initial determination that the penalty applied.
Passports can be denied to any person whom the IRS certifies as having seriously delinquent tax debt.
A recently enacted law requires penalties for failing to file certain information returns to be adjusted for inflation. The latest adjustments are announced in this guidance.
The guidance provides procedures to ensure consistency and efficiency in the IRS’s administration of the FBAR compliance program.
The Tax Court upheld the IRS’s imposition of penalties against a couple for marketing and promoting tax shelters based on the use of a corporation sole.
The Erwin case is an important reminder that an accountant can be held liable for a client’s unpaid employment taxes.
Seventh Circuit upheld a district court’s decision to spare Beanie Babies billionaire prison time for evading taxes by hiding assets in a Swiss bank account.
IRS Proposes Rule Updates and Clarifications to Penalty for Nondisclosure of Reportable Transactions
The IRS issued proposed regulations that would update and clarify the rules regarding the penalty for failure to disclose reportable transaction information.
The Tax Court held that a responsible person taxpayer was not entitled to currently not collectible status for her liability attributable to a trust fund recovery penalty and that adequate protection payments made to the IRS by her wholly owned corporation could not be applied to her liability.
This article examines recent developments in parallel civil and criminal investigations as they have been reinvented over the past decade.
Penalties apply for failure to report the information required under Secs. 6038 and 6038A by failing to timely file Form 5471, 5472, or 8865. There are two procedural paths for a taxpayer that files a late form.