The Obama fiscal year 2014 budget contains language that would require the United States to collect and exchange the same kinds of information under the Foreign Account Tax Compliance Act (FATCA) that the United States is seeking from other countries. The Obama administration may soon ask Congress for the power to require more disclosure by U.S. banks of…
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The IRS Can Read Your Emails If It Wants.
If you've been swapping emails with your accountant about the best way to avoid paying taxes, be aware: The IRS says it has the right to go into your account and read them. A report from the American Civil Liberties Union, which filed a Freedom of Information Act request to find out whether the IRS is…
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CCA Finds That Information Reporting Penalties Are Divisable Taxes For The “Full Payment Rule” for a Refund Suit.
In Chief Counsel Advice 201315017, the IRS has determined that the penalties under Code Sec. 6721 for failure to file an information return and Code Sec. 6722 for failure to furnish a correct payee statement are divisible taxes for purposes of establishing refund suit jurisdiction. The penalties are calculated on a per-transaction basis, and…
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More Unbelievable FBAR Penalties Cases!
A 1500% penalty rate on the taxes avoided/FBAR penalty, is imposed in a California case. Is a 1500% penalty constitutionally permissible? Of course the Defendant knowingly and voluntarily plead guilty, but should the IRS CID even be able to have the leverage to force someone to this type of penalty? FBAR: Isreal & Luxemborg a warning…
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