The IRS can assess restitution that a taxpayer was ordered to pay as part of his sentence for violating Sec. 7201.
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TOPICS / PROCEDURE
Collections, Liens & Levies
IRS finalizes tax preparer due-diligence regs.
The IRS issued final regulations on the penalty that applies to tax return preparers who fail to exercise due diligence in preparing returns for taxpayers who are claiming head-of-household filing status, the earned income tax credit, the child tax credit, the additional child tax credit, or the American opportunity tax credit.
Is your client the subject of an FBAR examination?
This article discusses a few key things practitioners should know about FBAR cases.
Some individual taxpayers get relief from underpayment penalty
The relief applies to individuals whose tax withheld and estimated tax payments equal at least 85% of the tax shown on their 2018 tax return.
Resolving federal tax liabilities
This article explains debt resolution methods, how tax practitioners can assist taxpayers in the process of resolving a liability, and how taxpayers can administratively appeal adverse IRS collection
determinations.
Actor’s failure to document financial condition dooms offer in compromise
It was not an abuse of discretion for an IRS settlement officer to reject an offer in compromise where the taxpayer failed to document his assets or financial condition.
Negotiation with collections officer is not administrative proceeding
The IRS abused its discretion in failing to consider the taxpayers’ proposed offer in compromise, installment agreement request, and economic hardship claim.
Avoiding an accuracy-related penalty through the reasonable-cause exception
By knowing the factors courts consider in determining whether a taxpayer meets the requirements for the reasonable-cause exception, and how the courts have applied the factors, tax advisers can help their clients properly mount a defense to an accuracy-related penalty.
Tax preparer due diligence rules are finalized
The IRS issued final regulations on the penalty that applies to tax return preparers who fail to exercise due diligence in preparing returns for taxpayers who are claiming head-of-household filing status, the earned income tax credit, the child tax credit, the additional child tax credit, or the American opportunity tax credit.
Cryptocurrency: Compliance challenges and IRS enforcement
This item discusses some key U.S. tax implications
and unanswered questions of cryptocurrencies and identifies possible avenues of relief for taxpayers with unreported income or assets connected to cryptocurrency.
IRS gives taxpayers penalty and late-election relief for Sec. 965 transition tax
The IRS announced relief from late-payment penalties and that it will allow late elections for taxpayers subject to the new Sec. 965 transition tax on deemed repatriated foreign earnings.
Failure to update penalty regulation costs IRS
The failure to update the regulations to reflect a statutory increase in the FBAR penalty amount prevents the IRS from assessing the full statutory amount of the penalty.
A review of adequate disclosure rules
Practitioners can protect themselves from significant
penalties by following the IRS’s ‘adequate disclosure’
procedures.
Sec. 6676 erroneous claim for refund penalty
The Sec. 6676 penalty is equal to 20% of the amount by which the claim for refund or credit exceeds the amount allowable for the tax year at issue.
First-time abatement: Procedure and case law updates
An automated process for first-time abatements could ensure consistent application of relief for taxpayers.
Knowledge of tax-related proceeding necessary for obstruction conviction
A taxpayer must be aware of a pending tax-related proceeding to be convicted of obstructing or impeding due administration of the Code.
The Offshore Voluntary Disclosure Program and cryptocurrency
The IRS is ending the Offshore Voluntary Disclosure Program just as its enforcement of cryptocurrency compliance increases.
Economic substance doctrine applied to conservation easements
The IRS stated it would challenge the tax benefits of certain syndicated conservation easement transactions.
Strategies for minimizing estimated tax payments
Taxpayers can use various techniques to minimize estimated tax payments throughout the year while also avoiding underpayment penalties.
Employment tax penalties: Let’s keep it civil
This article focuses on the potential criminal consequences that can arise when a business fails to collect or pay over withheld tax.
employee benefits & pensions
Profits interests: The most tax-efficient equity grant to employees
By granting them a profits interest, entities taxed as partnerships can reward employees with equity. Mistakes, however, could cause challenges from taxing authorities.
