According to Law360, Internal Revenue Code Section 965 as enacted by the Tax Cuts and Jobs Act imposes a one-time transition tax on the deferred earnings and profits of certain foreign corporations owned by U.S. persons. This provision was enacted as a result of the United States transitioning to a quasi-territorial tax system. As a…
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Time to File OVDP Refund Requests Based Upon Colliot?
On May 22, 2018 we posted A Taxpayer Victory on a FBAR Penalty Case - FBAR Limited to $100M! where we discussed the Colliot case, where a U.S. District Court found that a prior un-amended valid regulation, that caps penalties for willful violations of foreign bank account reporting at $100,000 controls even though under 31 U.S.C. § 5321,…
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IRS Has 6 New Compliance Campaigns Audit Strategies for LB&I
On February 7, 2017 we posted IRS Has 13 New Compliance Campaigns for LB&I Taxpayers where we discussed our previous posted on October 9, 2015 LB&I Agents Lose Autonomy To Centralized Office That Will Be Using Data to Identify Compliance Risks For Audit! that discussed the fact that Tax practitioners will face new questions from examination teams…
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Tax Havens Still Very Much Alive & Well!
According to National Bureau of Economic Research (NBER) there is over ARS220 billion in offshore accounts, the equivalent of almost 40 percent of Argentina’s GDP. The country ranks 5th globally for offshore account deposits, behind Russia, Saudi Arabia, Venezuela and the UAE. Drawing on newly published macroeconomic statistics, the National Bureau of Economic Research estimates the…
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