IRS Notice 2011-53 delays both the FATCA §1471 withholding and reporting requirements one year to January 1, 2014, and phases in those requirements over two years starting in 2014. The revised version of Notice 2011-53 extends the application of the phase-in to §1472 as well. We have provided a Table Below listing the details of the time…
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Lack of Meaningful Participation in Prior Case Provides Innocent Spouse Relief
The husband of a gambler who did not know that his wife was inaccurately reporting her gambling losses did not “participate meaningfully” in a prior Tax Court deficiency case the U.S. Tax Court held Sept. 26 and thus he is entitled to innocent spouse relief (Harbin v. Commissioner, T.C., No. 9994-07, 137 T.C. No. 7,…
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M&A Land Mark Victory cited in recent Florida Tech Advice
Florida - Gambling Ship Eligible for Exemption on Certain Receipts, Advisory Explains SUMMARY Facts: The taxpayer is a Florida Limited Liability Company organized in the state of Florida. The taxpayer will operate a gaming and entertainment ship, which will operate out of the Port Authority, Florida. Question: Is the taxpayer eligible for the partial exemption…
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U.S. campaign to catch tax cheats snaring Canadians
As U.S. tax authorities move to crack down on citizens living abroad, many living in Canada have been caught up in fear of massive penalties. Esther Thompson, 70, and her sister Betty, 69, both married to retired farmers living near Prince Albert, Sask., are among those who have come unhappily forward to the U.S. Internal…
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