Reuters is reporting that the current administration may soon ask Congress to require U.S. banks to disclose more information regarding foreign clients' account information. The Treasury's concentrated effort, on information-sharing, stems from the Foreign Account Tax...
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Department of Justices’ Patience with Taxpayers and Offshore Accounts is Running Thin
A recent Tax Notes Today article by Contributing Legal Editor, Jeremiah Coder, warns that the Internal Revenue Service's (IRS) Offshore Voluntary Disclosure Program (OVDP) may have limits which could have dire consequences for taxpayers that continue to hold out. Mr....
Court Allows the IRS to Issue John Doe Summons to UBS
Bloomberg is reporting that a federal judge has directed the Internal Revenue Service (IRS) to issue a summons requiring the Swiss bank Union Bank of Switzerland (UBS) to produce information about U.S. taxpayers who were trying to evade U.S. income taxes by holding...
District Court Prevents IRS Regulation of Tax Return Preparers…But the IRS Strikes Back
On January 28, 2013, in Loving v. IRS, the U.S. District Court for the District of Columbia found in favor of Sabina Loving and two other plaintiffs who challenged the Internal Revenue Service's (IRS) ability to govern tax return preparers pursuant to regulations...
Treasury and IRS Issue Final FATCA Regulations
The time for waiting is over! Today the Department of the Treasury and the IRS issued the long-awaited final regulations implementing the information reporting and withholding tax provisions of the Foreign Account Tax Compliance Act (FATCA). These regulations aim to...
California Supreme Court Will Hear Gillette v. Franchise Tax Board
On January 16, 2013, the California Supreme Court granted the Franchise Tax Board's (FTB) petition for review in Gillette Company v. California Franchise Tax Board, and will likely hear arguments sometime this spring. We have previously covered the Gillette case here,...
IRS Announces Annual Inflation Adjustments for 2013
The Internal Revenue Service announced its inflation adjustments for the 2013 tax year, including tax rate tables, and items from the American Taxpayer Relief Act of 2012.Some of the most notable tax items for 2013 include the following changes: Beginning in tax year...
I.R.S.’s Taxpayer Advocate 2012 Annual Report Calls for the Need to Simplify the Tax Code
The National Taxpayer Advocate, Nina Olson, delivered the Taxpayer Advocate's 2012 Annual Report to Congress emphasizing the need for lawmakers need to overhaul the tax code completely in order to reduce the "significant, even unconscionable, burden" placed on...
Estate Tax Questions Answered At Last
The American Taxpayer Relief Act of 2012, passed by Congress in the final hours of 2012 and signed by President Obama on January 1, 2013, includes significant estate and gift tax law.Among its many tax provisions, the 2012 Act makes permanent the $5,000,000 gift,...
U.S. and Norway Sign Competent Authorities Agreement Clarifying Sourcing of Income
Tax Analysts is reporting that on December 19, the IRS released an agreement signed by U.S. and Norwegian competent authorities that clarifies special sourcing provisions in the Norway-U.S. income tax treaty with regard to income received for performing...
