I recently attended an ABA conference where multiple representatives from the IRS including, Senior Litigation Counsel Kevin M. Downing, were speakers and they all reiterated that the IRS has a program in place to audit Quiet Filers, who chose not to make a voluntary disclosure but rather chose solely to amend their tax returns to…
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IRS Releases Guidance on Foreign Financial Asset Reporting
IRS NEWSWIRE WASHINGTON—The Internal Revenue Service in coming days will release a new information reporting form that taxpayers will use starting this coming tax filing season to report specified foreign financial assets for tax year 2011. Form 8938 (Statement of Specified Foreign Financial Assets) will be filed by taxpayers with specific types and amounts of…
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Temporary & Proposed Regulations on Reporting of Specified Foreign Financial Assets released by IRS
The Internal Revenue Service Dec. 14 released temporary regulations (T.D. 9567)relating to the provisions of the Hiring Incentives to Restore Employment (HIRE) Act that require foreign financial assets to be reported to IRS for taxable years beginning after March 18, 2010. The temporary regulations provide guidance concerning the requirement that individuals attach a statement to…
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Swiss Upper House Approves U.S.-Swiss Double Taxation Treaty
The Swiss parliament’s upper house gave its approval to proposed amendments to a new U.S.-Swiss double taxation treaty that would make it easier for U.S. authorities to seek information on secret bank accounts held by U.S. taxpayers with Swiss banks. The Council of States, the Swiss equivalent of the U.S. Senate, approved the amendments by a…
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