Recently the Supreme Court held in Kawashima v. Holder (Feb. 21, 2012) that filing a false tax return in violation of IRC Section 7206(1) as well as other criminal tax offenses are aggravated felonies which can result in deportation of a resident alien. Background, Mr. and Mrs. Kawashima were legal residents of the United States…
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Unique Identification Number Allows IRS to Identify Foreign Entities
A new IRS Webpage on how to file tax forms related to foreign interests using a unique reference identification number (URI) is designed to allow the Internal Revenue Service to more easily identify a taxpayer's foreign entities and compare their activities, or lack of activities, from year to year. Beginning with U.S. federal tax returns…
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FinCEN postpones mandatory FBAR e-filing
The IRS does not permit electronic filing of US income tax returns for preparers living outside the US. It remains to be seen if they will apply the same rule to FBAR forms. For 2011 FBAR forms should be manually filed as in the past. Failure to file FBAR forms on time may result in…
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IRS Criminal Investigations Unit obtains 94 Percent Conviction Rate.
According to Rick Raven, deputy chief of IRS investigations, the cases that IRS's criminal investigations unit sends to the tax division have ended up in a 94 percent conviction rate, making it the highest rate of conviction in law enforcement. Offshore tax evasion is taking up a lot of the unit's time, Raven says.…
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