Luxembourg has recently agreed to enter into the Model I FATCA Agreement, which provides for an automatic exchange of information between the Luxembourg and American fiscal authorities on bank accounts held in Luxembourg by citizens and residents of the United...
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IRS Reminds Those with Foreign Assets of U.S. Tax Obligations
Remember that FBAR reports are due for clients on June 28th, since there are no filing extensions on FBARs and the due date of June 30th falls on a Sunday this year. The filing deadline of June 15th for U.S. citizens and resident aliens living overseas or serving in...
IRS, Australia and United Kingdom Engaged in Cooperative Effort to Combat Offshore Tax Evasion
The tax administrations from the United States, Australia and the United Kingdom announced today a plan to share tax information involving a multitude of trusts and companies holding assets on behalf of residents in jurisdictions throughout the world.The three nations...
So you got a letter from the IRS — What now?
Now that April 15 has passed, many California taxpayers are breathing a sigh of relief that they don't have to deal with the IRS for another year. However, that may not be the case. It is in the days, weeks and even months following April 15 that the IRS sends letters...
California Court Holds Reasonable Cause for Penalty Abatement due to the Advice of a Professional only Qualifies when Ambiguity Exists for the Taxpayer
The Ninth Circuit Court of Appeals held that erroneous advice from an accountant that an estate tax return (IRS Form 706) could be extended for filing and payment purposes by one year did not qualify for penalty abatement as "reasonable cause."In Knappe v. United...
The IRS and California gain over $1B from Zuckerberg
Most everyone knows that Mark Zuckerberg is the founder and CEO of the popular social media site Facebook. What may not have been as well known until recently is that Zuckerberg owes more than $1 billion in taxes to the IRS and the state of California. That represents...
Court Holds That Compensation Paid to S-Corporation’s Sole Employee Was Unreasonable
Recently, in Watson, P.C. v. Unites States, 668 F.3d 1008 (8th Cir. 2012), the Court of Appeals held that the Internal Revenue Service (IRS) properly re-characterized S-Corporation distributions as wages and were therefore subject to employment taxes. Watson should...
IRS claims it can read your e-mail without a warrant
Recently, the IRS has publicly stated their position that there is no expectation of privacy regarding electronic communications, and that they may be able to view your electronic communications without a warrant.To read more, click here.
No IRS Form 8938 (Statement of Specified Foreign Financial Assets) is Required to File with Forms 1120, 1120S, 1065 and 1041 for 2012
Domestic Entity filers for tax year 2012 are not required to file Form 8938. The IRS anticipates issuing regulations in the future that will require a domestic entity to file Form 8938; but, until such regulations are issued, only individuals must file Form 8938....
Tax Court Limits Northern California Couples’ Real Estate Rental Loss Due To Passive Activity Rule
With the economic downturn the U.S. tax court has seen its fair share of cases tackling the limitation of real estate losses.In Hassanipour v. Commissioner, the U.S. Tax Court, held that a couple's losses from their rental activities were limited under IRC section...
