Swisspartners Investment Network AG, a Swiss-based asset management firm, and three of its wholly-owned subsidiaries (collectively, the Swisspartners Group), entered into a non-prosecution agreement (NPA) with the U.S. Attorney’s Office for the Southern District of New York and agreed to pay $4.4 million to the United States. The NPA was entered into based…
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Tax Court Upholds Negligence Penalty But Not Fraud Penalty
The Tax Court has upheld IRS's determinations with respect to the car and truck expenses that a married couple was entitled to deduct, finding that their records were inconsistent and didn't support the higher amounts claimed. However, the Court declined to impose a fraud penalty against the couple, concluding that the errors on their returns…
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IRS Released Forms 8966 & 1042 Updated For FATCA Reporting Requirements
On March 5, 2014 the Internal Revenue Service released new versions of three critical forms to help financial institutions and withholding agents meet the requirements of the Foreign Account Tax Compliance Act, including draft versions of Form 8966 and Form 1042-S, and a final version of Form 1042. Form 8966, FATCA Report, is a new form…
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Fast Track Settlement Program – When & How To Use It During an Audit
FTS is an optional strategy to reach resolution when the SB/SE examiner and manager and the taxpayer have exhausted established issue resolution strategies. For eligible cases, FTS allows taxpayers that have unagreed issues to work with SB/SE Examination and the Office of Appeals (Appeals) to resolve the issues while the case remains in SB/SE's jurisdiction.…
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