Speaking at a recent international tax enforcement conference, National Taxpayer Advocate Nina Olson suggested that IRS implement an approach to its Offshore Voluntary Disclosure Initiative (OVDI) that would only penalize taxpayers based on their level of non-compliance. As Olsen noted at a conference sponsored by the Tax Section of the American Bar Association, there…
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IRS Advisory Council Issues 2012 Annual Report
IR-2012-92, Nov. 15, 2012 WASHINGTON — One of the Internal Revenue Service’s main advisory panels for tax administration today issued its 2012 annual report, covering a range of key issues affecting taxpayers. The Internal Revenue Service Advisory Council (IRSAC) issued its report at a public meeting. IRSAC’s primary purpose is to provide an organized…
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U.S. Treasury Release Second Model Intergovernmental Agreement
On Thursday, November 8, 2012 we posted U.S. Engaging with More than 50 Jurisdictions to Curtail Offshore Tax Evasion. Yesterday November 14, 2012, Treasury published the Model Intergovernmental Agreement for Cooperation to Facilitate the Implementation of FATCA (Model 2 Agreement to Implement FATCA). The Treasury Department and the IRS will finalize the regulations implementing FATCA…
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IRS Whistle Blower Program & The Necessity of Legal Cousel!
We oringally posted Attention All Whistle Blowers, The IRS Needs $$$! on Tuesday, October 9, 2012; where we discussed New Section 7623(b). Under it, awards to whistleblowers are no longer discretionary. Now, the whistleblower“shall” receive 15 to 30 percent of the collected proceeds. That’s shall, not may. Procedural safeguards were added too. The 2006 law…
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