The IRS has revised its plan to revoke Individual Tax Identification Numbers (ITINs) after five years of issuance based on the response from taxpayers and their representatives. Instead, beginning in 2016, the IRS will only retire those ITINs which have not been used...
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Tax Court rejects $10.7 million in transferee assessments proposed by the IRS
Last week the Tax Court issued an opinion involving proposed transferee liability assessments in excess of $10.7 million in which it rejected the IRS's proposed application of federal law to recast a transaction under the substance over form doctrine. Swords Trust v....
Two Free IRS Webinars for Small Businesses in May 2014
According to the Internal Revenue Service (IRS), it will hold two free webinars for small businesses on this year's "Small Business Week," May 12 to 16. The Webinars focus on several key tax benefits and a special relief program for employers who reclassify their...
Court finds settlement proceeds from mortgage fraud lawsuit were not includible in income
In a Summary Opinion, the Tax Court found that a taxpayer did not have $10,000 in unreported income with regard to settlement proceeds resulting from a mortgage fraud lawsuit. Kadir v. Commissioner, T.C. Summ. Op. 2014-43.In Kadir, the taxpayer had refinanced his...
New FATCA Guidance
The IRS provides further clarification and announces its intention to further amend certain Regulations concerning FATCA. In order to facilitate an orderly transition for withholding agents and Foreign Financial Institutions, the years 2014 and 2015 will be treated as...
The Countdown Begins as the IRS prepares to Release the First List of Approved Foreign Financial Institutions in Compliance with FATCA
The IRS recently issued Announcement 2014-17, providing an update on jurisdictions treated as having intergovernmental agreements (IGAs) with the United States in order to implement the Foreign Account Tax Compliance Act (FATCA). As of the date of the announcement,...
Taxpayers can waive the attorney-client privilege by raising good faith and state-of-mind defenses during litigation
The Tax Court recently issued an opinion in AD Investment v. Commissioner, 142 T.C. No. 13, in which the Court granted the IRS's motion to compel the production of documents. The controversy arose in the context of two consolidated Tax Court proceedings involving...
IRS releases 2014 version of “The Truth About Frivolous Tax Arguments”
Last Friday the IRS published an updated version of its publication "The Truth About Frivolous Tax Arguments." This publication provides a list of common frivolous arguments advanced by individuals and groups who oppose compliance with the federal tax laws.Individuals...
IRS Reminds Those with Foreign Assets of U.S. Tax Obligations
The Internal Revenue Service reminds U.S. citizens and resident aliens, including those with dual citizenship who have lived or worked abroad during all or part of 2013, that they may have a U.S. tax liability and a filing requirement in 2014.The filing deadline is...
Little Known Facts About Amending Tax Returns with the IRS
What happens when you realize you made an error on your tax return? Most people think they should file an amended tax returns, and in most cases, that would be correct; however, sometimes it is unnecessary. According to the IRS, if you made a math error, the IRS will...
