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Monthly Archives: September 2014

IRS Launches Offshore Promoter Audits!

IRS Launches Promoter Audits Of Captive Managers Suspected Of Abusive Practices - Forbes forbes.com We have now discovered that in 2013 the IRS finally launched its long-anticipated investigation of the managers of smallish insurance companies. This has finally culminated in the IRS issuing notices this year that it is conducting so-called “promoter audits” of these…
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Are Gift Tax Audits on the Rise?

Gift Tax Audits wealthmanagement.com The IRS 2012 Data Fact Book reports that 258,393 gift tax returns (Forms 709) were filed that year compared to 219,544 in 2011.  The most striking difference between the two years is the aggregate amount of the gifts, which totaled about $135 billion in 2012, reflecting an increase of $84 billion,…
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Estate Tax Audits Are on the Rise

Expect An Audit: The Estate Tax Audit Rate Is Skyrocketing wealthmanagement.com There's an important—yet unspoken—phenomenon in the world of estate tax: As the number of estate tax filings has been decreasing nationwide since 2001, there's been a corresponding increase in the Internal Revenue Service's audit coverage rate of estate tax returns—from 20 percent to nearly…
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So What Does “Non-Willful” Really Mean Under The Streamlined OVDP?

It appears that whatever Non-Willful means outside of the OVDP streamline program; it is certainly being applied differently in evaluating a Taxpayer’s ability to transition from the OVDP program into this new 2014 streamline program.  Below I've attached two excerpts one from Forbes and one from BNA Daily Tax Report, both verifying that taxpayers who…
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