On June 18, 2013, the Acting LB&I Commissioner issued a directive (LB&I Control No: LB&I-04-0613-004) to LB&I employees announcing that for all IDRs issued after June 30, 2013: The examiner must identify and state the issue that has led the examiner to request the information included in the lDR. The examiner must discuss the lDR…
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IRS Pronouncements Make Offers in Compromise Less Available.
The IRS issued memorandum SBSE-05-1013-0076 to its Collection employees who are working Offer in Compromise cases, providing them guidance on when Offers should be rejected under "Not in the Best Interest of the Government" or "Public Policy" basis. This guidance supplements the procedures found in Internal Revenue Manual (IRM) 5.8.7.7, Rejection; IRM 5.8.7.7.1, Not in the…
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IRS Releases 50 Pages of FATCA Guidance!
The IRS released today October 29, 2013 Notice 2013-69 which provides guidance for foreign financial institutions (FFIs) entering into an FFI agreement with the IRS to be treated as a participating FFI or Reporting Model 2 FFI under the provisions commonly referred to as FATCA. This notice includes a draft copy of the FFI agreement,…
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Another Swiss Bank Bites The Dust!
Bank Frey has become the second of Switzerland's smaller banks to announce it is ceasing operations as a result of the US government's drive against cross-border tax evasion. The organisation, founded in 2000, says it is solvent and will not be liquidated. It has merely decided that the costs associated with the US tax…
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