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Monthly Archives: December 2013

New User Fees for Processing Installment Agreements and Offers in Compromise



Effective Jan. 1, 2014, processing fees for standard installment agreements and doubt as to collectability offers will increase. Fees for direct debit installment agreements are unchanged. Low income fees and fee waivers are also unchanged. 

The notice of proposed rule making proposed to increase the fee under § 300.1 for entering into an installment agreement from $105 to $120 and to increase the fee under § 300.2 for restructuring or reinstating an installment agreement from $45 to $50.

Under the notice of proposed rule making, the fee for a direct debit installment agreement remained $52, and low-income taxpayers, as defined in § 300.1(b)(2), would continue to pay $43 for any new installment agreement, including a direct debit installment agreement. The notice of proposed
rule making also proposed to increase the fee under § 300.3 for processing an offer in compromise from $150 to $186.

Offers based on doubt as to liability and offers from low-income taxpayers continue to be excepted from a user fee.

The new fee rates for both installment agreements and offers in compromise will be effective January 1, 2014.

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U.S. Signs 6 More FATCA Agreements!



The US Treasury Department's web site indicates that the U.S. has signed FATCA agreements with:

  1. Bermuda
  2. Guernsey
  3. the Isle of Man, 
  4. Jersey
  5. Malta and 
  6. the Netherlands.

The US Treasury Department's web site also reflects that with the six new agreements are total of 18 of such signed intergovernmental agreements (IGAs). 

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FATCA FFI List Resources and FFI List FAQs are Now Available

What taxpayers representatives should be paying attention to in these FATCA discussions, among other things, is that the form of the FATCA submissions entitled "Schema" is a uniform computer readable report. This is the same language/requirement which is being utilized in discussions regarding intergovernmental agreements.

So effectively, in the not-too-distant future, we may be seeing foreign banks submitting their "Schema" to their government to be shared with the US and other foreign governments; which can then be used by the IRS or the other home country to match up the information in the "Schema" against that depositors local tax report!

Some of the requirement currently being discussed include that these "Schema" contain the taxpayers  home country identification number. So for a US taxpayer it would contain their Social Security number.

Where that happens, tax advisers need to advise their clients that it's no longer a question of if; rather it's a question of when, the US and other governments are able to match the information from these intergovernmental agreements to an individual US taxpayers transcript information or other country's tax information.

No one can tell exactly when this ability to cross match foreign information with US  taxpayers transcripts will occur; however a good guess would be as soon as 3 to 5 years in the future; given all the logistics associated with such a program.

Do You Have Unreported Foreign Income?
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Marini & Associates, P.A.  
 
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Marini & Associates, P.A. Wishes You Happy Hollidays!


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Merry Christmas,
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New Year!


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