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Monthly Archives: October 2018

Qualified Opportunity Fund Benefits Foreign Investors Also.

IRS has issued proposed regs that describe and clarify the requirements that must be met by a taxpayer in order to defer the recognition of gains by investing in a qualified opportunity fund (QOF) under Code Sec. 1400Z-2, as added by the Tax Cuts and Jobs Act (TCJA, P.L. 115-97; 12/22/2017). The proposed regs provide…
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OVDP Ended Sept. 28 – So Now What?

We originally posted on March 13, 2018 IRS to End OVDP Sept. 28 - Last Chance for Taxpayers With Undisclosed Foreign Assets! where we discussed that the Internal Revenue Service announced in IR-2018-52 that it will begin to ramp down the 2014 Offshore Voluntary Disclosure Program (OVDP) and close the program on Sept. 28, 2018. The…
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The IRS Whistleblower Reward Program

The IRS estimates that the United States loses $450 billion per year to tax evasion. In 2006, Congress enacted legislation providing robust incentives for whistleblowers to report tax fraud.  Under 26 USC § 7623(b), the IRS is required to issue an award to tax whistleblowers of 15% to 30% of proceeds collected from tax fraud or tax underpayments  …
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