More than 100 jurisdictions have concluded negotiations on a multilateral instrument that will swiftly implement a series of tax treaty measures to update international tax rules and lessen the opportunity for tax avoidance by multinational enterprises. The new instrument will transpose results from the OECD/G20 Base Erosion and Profit Shifting Project (BEPS) into more than…
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Ending Face To Face Appeals Meeting Not a Good Idea!
On September 20, 2016, we posted No More Face to Face Meetings at IRS Appeals Division? where we discussed that the IRS announced that effective Oct. 1, 2016, it will rarely conduct Appeals Conferences in person. More specifically, Internal Revenue Manual (IRM) 8.6.1.4, blandly entitled “Conference Practices,” provides that ALL conferences will be held by telephone…
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What to do When You Receive an IRS Notice?
The IRS sends many, many, many, letters and correspondence before they levy or garnished any Taxpayer's wages, bank accounts, or other assets. Many taxpayers take the ostrich approach and ignore the problem, in hopes that it will go away. If you’re facing an IRS Problem, appropriate action can go a long way towards resolving it!…
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Using an Offshore Insurance Wrapper to Hold Your Foreign Wealth? The IRS May Have Some Questions For You!
According to a BNA Daily Tax Report dated 05/31/2017 entitled Tax Prosecutions: Five Questions With Former DOJ Tax Head Caroline Ciraolo when asked "With the success of the Swiss Bank Program, have there been plans to announce a similar initiative?" She respond by saying that when she left the DOJ earlier this year, the department wasn't planning to…
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