The IRS posted on June 2, 2014 the first list of about 77,000 foreign financial institutions around the world that have registered to comply with the Foreign Account Tax Compliance Act which were approved as of May 23, 2014. The list is searchable by GIIN or Financial Institution Name. The list is located on the…
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Assertion of Reasonable Cause Defense to Penalty Results in Loss of Attorney-Client Privilege
Chuck Rubin Posted on RUBIN ON TAX: ASSERTION OF REASONABLE CAUSE DEFENSE TO PENALTY RESULTS IN LOSS OF ATTORNEY-CLIENT PRIVILEGE, where he discusses that written and oral communications between a client and his or her attorney are generally privileged. This includes communications regarding taxes. In a recent Tax Court case, an example of “the exception…
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What To Do If Your FATCA Registration Has Been Put Into “Registration Under Review” Status?
My FATCA account status is “Registration Under Review.” What should I do? According to the IRS, if your registration has been put into “Registration Under Review” status, please contact e-Help at 1-866-255-0654 begin_of_the_skype_highlighting 1-866-255-0654 FREE end_of_the_skype_highlighting and indicate that your registration is in “Registration Under Review” status. In addition, please provide: (1) the Name of the Financial…
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IRS Successfully Assesses 50% FBAR Penalty for “Quiet Disclosures”!
We have previously posted on Tuesday, May 13, 2014, "Zwerner' FBAR Case Goes To Trial 5/20/14 and Will Test The IRS' Ability to Assert The Willfulness Penalty For Multiple Years." where we discussed the U.S. government's Complaint to collect multiple civil FBAR penalties in the amount of $3,488,609.33 previously assessed against Carl R. Zwerner of…
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