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Monthly Archives: May 2018

A Taxpayer Victory on a FBAR Penalty Case – FBAR Limited to $100M!

According to Law360, the Internal Revenue Service went beyond the cap on civil penalties it can assess for undisclosed offshore bank accounts, a Texas federal judge has ruled, rejecting the agency’s argument that regulations limiting the amount are implicitly invalid. The IRS had sued a Texas man to collect hundreds of thousands of dollars in…
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Taxpayer's Domain Name is Protected From Tax Levy!

In Chief Counsel Advice 201818015, the IRS has determined that an internet domain name is "intangible personal property" for purposes of the procedural levy protections afforded to certain property used by a taxpayer in his or her trade or business.  After a tax has been assessed, IRS must, within 60 days, deliver or mail to the…
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Whistleblower Requests Deadline Extension to File With Tax Court

According to Law360, a tax whistleblower said the U.S. Tax Court should hear his untimely petition because the Internal Revenue Service letter declining his claim was vague and failed to tell him he could appeal, according to a brief filed Tuesday with the D.C. Circuit. David Myers filed a whistleblower claim with the IRS in 2009 and…
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IRS Withholding on Crypto Cryptocurrency Coming Soon!

According to Law360, The Internal Revenue Service will begin this year to more strictly enforce the requirement to withhold taxes for cryptocurrency payments to nonresident aliens, an attorney who has represented clients in related matters said at a Saturday tax conference in Washington, D.C. While the requirement to withhold 30 percent of payments to nonresident aliens…
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