PALO ALTO—U.S. participation in exchange of information agreements does not mean that the Internal Revenue Service automatically releases taxpayer information to any nation that requests it, Douglas O'Donnell, IRS assistant deputy commissioner (International), said Jan. 20. “Every country that's on the receiving end of a specific request is paying very close attention to the narrative…
Read more
Romney offshore accounts contain up to $32 million.
The Miami Hearld reports that Republican presidential candidate Mitt Romney owns investments worth between $7 million and $32 million in offshore-based holdings, which are often used legitimately by private equity firms to attract foreign investors. Such offshore accounts also can enable wealthy investors to defer paying U.S. taxes on some assets. The six Romney offshore holdings…
Read more
IRS's Right to Examine a Taxpayer's E-Mails
A recent advisory issued by the Chief Counsel's Office of the Internal Revenue Service ("IRS") sets forth the IRS's position on the procedures that its agents must follow in order to obtain a taxpayer's e-mails from his or her Internet service provider ("ISP"). In I.R.S. Chief Counsel Advisory("I.R.S. C.C.A.") 2011-41-017 (July 8, 2011), the IRS…
Read more
What Type & Form of Disclosure is Necessary to Avoid Penalties?
Revenue Procedure 2012-15 updates Rev. Proc. 2011-13, 2011-3 I.R.B. 318 and identifies circumstances under which the disclosure on a taxpayer’s income tax return with respect to an item or a position is adequate for the purpose of reducing the understatement of income tax under section 6662(d) of the Internal Revenue Code and the purpose of…
Read more
