A Massachusetts woman whose joint bank account was seized by the Internal Revenue Service is entitled to an innocent spouse relief refund because state law says she owns half of the funds in the account, the U.S. Tax Court held Jan. 11 (Minihan v. Commissioner, T.C., No. 26595-09, 138 T.C. No. 1, 1/11/12). Writing for…
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Tax Evasion Sharpen IRS Focus on International Issues
The Internal Revenue Service is increasing its efforts to tackle international issues involving employee benefit plans as more business is done globally and as tax evasion through the use of offshore accounts grows, speakers said Jan. 11 at a benefits conference. “Experts estimate that Americans now have $1 trillion—trillion with a ‘t'—in assets offshore and…
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National Taxpayer Advocate battles IRS on terms of offshore voluntary disclosure program
The National Taxpayer Advocate (NTA) has issued a Taxpayer Advocate Directive (TAD), followed by ensuing correspondence between IRS and the NTA, alleging unfair treatment of certain participants in the 2009 offshore voluntary disclosure program (OVDP). According to the NTA, a memo issued by IRS on March 1, 2011 was inconsistent with earlier guidance from 2009…
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Switzerland Eases Rules on Account Data Transfer for U.S. Clients of Swiss Banks
The government of Switzerland has agreed to ease existing rules on the transfer of information on secret Swiss bank accounts of U.S. clients in a further effort to diffuse tensions with the United States over funds hidden away in Swiss banks. The Swiss government announced Nov. 16 that the Federal Council, the government's executive arm,…
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