In Chief Counsel Advice 201315017, the IRS has determined that the penalties under Code Sec. 6721 for failure to file an information return and Code Sec. 6722 for failure to furnish a correct payee statement are divisible taxes for purposes of establishing refund suit jurisdiction. The penalties are calculated on a per-transaction basis, and…
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More Unbelievable FBAR Penalties Cases!
A 1500% penalty rate on the taxes avoided/FBAR penalty, is imposed in a California case. Is a 1500% penalty constitutionally permissible? Of course the Defendant knowingly and voluntarily plead guilty, but should the IRS CID even be able to have the leverage to force someone to this type of penalty? FBAR: Isreal & Luxemborg a warning…
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The US Tax System Is Stacked Against The 99%.
The Great Divide: A Tax System Stacked Against the 99 Percentopinionator.blogs.nytimes.com The glaring unfairness of the United States tax system, with its myriad loopholes and special provisions for the wealthy, undermines not only economic growth, but the sense of shared purpose that is vital for democracy. Read more at: Tax Times blog
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Cayman and BVI to Agree to FATCA with US & Bahamas will Decide on FATCA by June.
We originally posted UK mini-FATCA Agreements Spells The End for UK Tax Haven Territories! on Monday, November 26, 2012. The UK and some other European countries have negotiating FATCA agreements with the US. The British Virgin Islands plan to sign a Model 1 FATCA agreement with the US, in the BVI's case a non-reciprocal…
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