The Commissioner of Internal Revenue, John Koskinen , put the international tax bar in suspense when he announced in a major speech on June 3, 2014, that very shortly, the IRS is considering publishing something which is supposed make it possible for millions of...
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IRS Innocent Spouse Relief
When a married couple files a joint tax return, each spouse is jointly and severally liable for the tax showing due on that tax return, and any subsequent audit adjustments the IRS may make. This means each spouse is responsible for the entire tax bill independently of the other. This doesn’t mean the IRS is doubling the tax, it just…
IRS Collection Appeals
The IRS provides administrative appeals procedures for a variety of situations. The focus of this blog is IRS appeals as they relate the resolution of an assessed federal tax debt. I will save for another day appeals procedures applicable to other issues like appeals of audit determinations or FBAR penalties. Here is a brief overview of common appeals procedures in…
ANOTHER FATCA DELAY: Good for the Banks but Nothing for Americans Abroad
In a ten page notice released late last Friday afternoon, the IRS published additional FATCA guidance, which at first glance may lead some wishful thinkers to conclude that the government is never going to be able to pull this FATCA thing off. (See IRS Notice...
COUNT DOWN TO FATCA: FATCA MYTHS AND FACTS I
With the July 1, 2014, FATCA effective date quickly approaching, it is finally front page news. Practitioners who are following FATCA closely have noted that the emphasis has shifted slightly from the onerous and unfair injustice FATCA imposes on Americans abroad and...
Opt Out of Offshore Voluntary Disclosure Program? We Need To See the National Office Appeals Coordinated Issues Paper Now!
An emerging issue for practitioners engaged in the offshore voluntary disclosure arena is collecting intel on what exactly the field offices are being told by the National Office about how to resolve opt out cases. A client can choose to opt out at any time assuming...
Some Thoughts on the National Taxpayer Advocate’s 2013 Annual Report to Congress
The National Taxpayer Advocate recently released its 2013 annual report to Congress on the performance of the IRS. Here is my two-cents on three of the most serious problems at the IRS according the Taxpayer Advocate: 1. The IRS should adopt a taxpayer bill of rights. I agree whole heartedly there should be a taxpayer bill of rights. However, the…
FATCA: “There’s No Point In Complaining. It’s Here To Stay.”
Last week on the “FATCA” LinkedIn group, a member wrote the following: “Why are so many people complaining about FATCA and crying FOUL!!!!! Just get on with it, it’s here to stay. It’s everyone, everything, everywhere…The sooner it’s embraced, the better the chance...
ONE GOOD REASON TO DO SOMETHING NOW ABOUT YOUR FOREIGN ACCOUNT: KEEP YOUR CHILDREN AND HEIRS FROM LOSING THEIR INHERITANCE TO GOVERNMENT FINES AND LAWYERS FEES
We have spoken before about the agonizing decision many people are facing today about what to do about their secret foreign accounts. This article applies especially to those who are getting on in years and may be inclined to just blow off foreign account/asset...
IRS Installment Agreement: An Option for IRS Tax Relief
Taxpayers unable to pay their IRS tax debts in full in a single payment have a number of available options. One of those options is to establish a payment plan with the IRS, which is commonly referred to as an installment agreement, or IA. An installment agreement allows taxpayers to make monthly payments to repay tax debts over time rather…