According to JDSUPRA, The American Bar Association has written to the US Internal Revenue Service, asking it clarify whether assets held as cryptocurrencies such as Bitcoin are subject to the Foreign Bank Account Reports (FBAR) and Form 8938 reporting rules. IRS Notice 2014-21asserted that cryptocurrencies were 'property' rather than currencies for federal income tax purposes but…
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IRS Searching For Non-Compliant Non-Residents'!
According to Law360, the Internal Revenue Service announced on May 14, 2018 that it will undertake a campaign to increase compliance for rules involving nonresident aliens' tax treaty exemption claims. Because the statutes involving income-based tax treaty exemption claims can be confusing, the IRS' Large Business and International Division will focus on education and outreach…
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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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