On Thursday, November 8, 2012 we posted U.S. Engaging with More than 50 Jurisdictions to Curtail Offshore Tax Evasion. Yesterday November 14, 2012, Treasury published the Model Intergovernmental Agreement for Cooperation to Facilitate the Implementation of FATCA (Model 2 Agreement to Implement FATCA). The Treasury Department and the IRS will finalize the regulations implementing FATCA…
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IRS Whistle Blower Program & The Necessity of Legal Cousel!
We oringally posted Attention All Whistle Blowers, The IRS Needs $$$! on Tuesday, October 9, 2012; where we discussed New Section 7623(b). Under it, awards to whistleblowers are no longer discretionary. Now, the whistleblower“shall” receive 15 to 30 percent of the collected proceeds. That’s shall, not may. Procedural safeguards were added too. The 2006 law…
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IRS Revises Form 4180 to Give Revenue Officers Ability to Expedite TFRP Interviews
The Internal Revenue Service released (SBSE-05-0812-065) on revisions to Form 4180, Report of Interview with Individual Relative to Trust Fund Recovery Penalty or Personal Liability for Excise Taxes. Specific guidance on how the revised Form 4180 should be used is as follows: Form 4180 -Page 1 Page 1 incorporates core willfulness and responsibility questions to support assertion recommendations…
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FATCA Intergovernmental Agreements
.width250 { display:none; } We originally posted on Thursday, November 8, 2012, U.S. Engaging with More than 50 Jurisdictions toCurtail Offshore Tax Evasion “Global cooperation is critical to implementing FATCA in a way that is targeted and efficient,” said Treasury Assistant Secretary for Tax Policy Mark Mazur. “By working cooperatively with foreign governments and…
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