With the budget reductions and losses in staff over the past several years, the IRS has been forced to do more with less. Therefore, the IRS has turned to big data analytics to make up for its loss of personnel and the impact of the budget reductions. Analytics entails the obvious benefit of efficiencies in…
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Magistrate Holds That Facebook Does Not Have a Right to Go to Appeals!
According to Law360, a California federal judge has granted the Internal Revenue Service’s motion to dismiss a $7 billion lawsuit brought by Facebook Inc. that alleged the IRS unjustly denied the social media company’s right to appeal the agency’s decision to adjust its taxes after an audit of its returns. U.S. Magistrate Judge Laurel Beeler…
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IRS Provides for Overpayments to be Applied to Taxpayer’s Remaining 965 Installment Liability?
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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