In a recently released legal memorandum, the Internal Revenue Service (IRS) ruled that taxpayers' losses resulting from investments in funds that were used to operate a Ponzi scheme are theft losses under § 165, even though the taxpayers invested through...
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IRS Criminal Investigation Statistics
The IRS has published the new 2011 Data Book, which is available here. The book contains various interesting statistics relating to the IRS's criminal investigation function.Table 18, Criminal Investigation Program, by Status or Disposition, Fiscal Year 2011 is...
IRS Issues Grants Relief to Some MF Global Victims
The IRS just announced penalty relief for any farmers who had to file their return after March 1 due to delays associated with the MF Global bankruptcy case. This new release indicates the magnitude and far-reaching implications associated with untangling MF Global's...
IRS regulations and mortgage modifications
Many California residents may have heard of the multi-state settlement that was reached recently with many of the nation's largest lenders. The settlement includes a provision under which lenders will reduce a portion of the principal on some mortgages. However,...
Advance Pricing Agreements and Competent Authority
The IRS is seeking public comment in advance of issuing updated published guidance with respect to requests for Advance Pricing Agreements and Competent Authority assistance. The IRS announced certain organizational and administrative changes and...
IRS Recruiting Talent To Crack Down On Transfer Pricing
Reuters is reporting that despite the Internal revenue Agency's (IRS) 2012 fiscal budget cut of 2.5%, newly appointed Transfer Pricing Director, Samuel Maruca, is recruiting talent to crack down on companies that shift their profits from country to country in order to...
Deadline is approaching for overseas residents to file income tax returns
U.S. citizens and resident aliens residing overseas or those serving in the military outside the U.S. on April 17, 2012 have until June 15, 2012 to file their federal income tax returns. For information on forms, world-wide income, foreign earned income exclusion and...
A Reminder to File IRS Form 8938, Statement of Specified Foreign Financial Assets
Most taxpayers with a reporting requirement for their interests in specified foreign financial assets must file their first IRS Form 8938 with their 2011 income tax return. The Foreign Account Tax Compliance Act (FATCA), enacted in 2010, requires certain U.S....
IRS Offers Expanded Installment Agreements and New Penalty Relief
It seems that the Internal Revenue Service is starting to take note of the sluggish economy and its effect on taxpayers. Today, the IRS announced a major expansion of its "Fresh Start" initiative aimed at helping struggling taxpayers, by making Installment Agreements...
IRS Holding $1 Billion in Unclaimed Refunds.
On February 23rd, the Internal Revenue Service said it is holding more than $1 billion in unclaimed refunds for U.S. taxpayers who didn't file federal income tax returns for the 2008 tax year. Generally, in cases where a tax return was not filed, the law provides...
