Under the check the box rules, entities owned by one person can often be disregarded for federal tax purposes. Such entities are referred to as "disregarded entities." As time has progressed since the passage of the check the box rules, the IRS has created more and more exceptions to the disregarded treatment. The following is…
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CPA Advice May Not Constitute Reasonable Cause to Stop FBAR Penalties
Taxpayers have been able to rely on advice from their accountants and CPAs to meet the complicated tax filing imposed by the U.S. Tax Code. But a case currently pending in the U.S. Court of Federal Claims suggests that CPA advice may not be enough to stop the IRS from assessing FBAR penalties for non-willful reporting violations.…
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IRS CI Forming 2 New International Criminal Units Driven By Data Mining!
On September 7, 2012, we posted IRS’s Voluntary Disclosure Data-Mining Program where we discussed that the use of data-mining technology is widespread and the Internal Revenue Service has adopted it to find taxpayers with undisclosed offshore bank accounts. U.S. taxpayers who are still considering whether to disclose their accounts need to understand that IRS’s data-mining software increases…
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4TH Cir DCA Denies Taxpayers Right to Switch from OVDP to Streamlined
On May 30, 2017 we posted Offshore Tax Suit To Switch From OVDP To Streamline Doesn’t Block Collection where we discussed that three taxpayers seeking to switch over to the IRS’ new “streamlined” compliance program for unreported offshore income argued to a D.C. Circuit panel that their lawsuit is not foreclosed by the Anti-Injunction Act's bar on…
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