The Internal Revenue Service hasn’t done enough to improve its procedures for reviewing amended tax returns to reduce erroneous and fraudulent tax refunds, according to a new report. The report, from the Treasury Inspector General for Tax Administration, followed up on earlier reports by TIGTA that found risks of fraudulent and erroneous tax refunds from…
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No Statute of Limitations Defense Where Fraud is Involved!
The Tax Court found in Kohan, TC Memo 2019-85 that a dentist's underreporting of income was due to fraud. Therefore, there was no period of limitations to assess the taxes he owed. IRC Sec. 6501(a) generally requires the IRS to assess a tax within three years after the filing of a return. However, when a taxpayer has filed…
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Tax Treaties Face Additional Obstacles After 10 Years of Delay
On July 31, 2019 we posted Senate OKs Tax Treaties With Spain, Japan, Switzerland & Luxembourg, where we discussed that Senate approved on July 17, 2019 three bilateral tax treaties with Switzerland, Luxembourg and Japan, one day after approving a treaty with Spain.The treaties were approved after years of inaction on the agreements, a development welcomed by…
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LLB Verwaltung (FKA Liechtensteinische Landesbank) Agrees With IRS & Is Turning Over Names of US Customers
On September 3, 2018 we posted 150 Offshore Banks & Now Financial Advisors Are Turning Over Your Names To The IRS - What Are Your Waiting For?, we discussed that the IRS keeps updating its list of foreign banks which are turning over the names of their US Account Holders, who where then subject to a 50% (rather than 27.5%) penalty in…
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