IRS Closes In On Secret Caribbean Accounts
The IRS is continuing to crack down on undisclosed foreign accounts. One common location for offshore accounts - the Caribbean - is now facing increasing scrutiny by the IRS.To read more, click here.
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Supreme Court Holds that Taxpayer Entitled to Foreign Tax Credit in PPL v. Commissioner
On May 20, 2013, the Supreme Court decided PPL Corp. v. Commissioner, holding that a British "windfall tax" imposed on privatized British companies has the predominant character of an excess profits tax and is therefore creditable under Internal Revenue Code (IRC)...
This time it’s the IRS that’s being investigated
Many in California have been subjected to scrutiny from the IRS. Well, this time, it's the IRS that's being investigated. The U.S. Attorney General instructed the FBI to begin an investigation into how the IRS has dealt with certain political groups that are...
Luxembourg Agrees to Share Information with the U.S.
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...
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...
Husband and Wife Indicted for Hiding Millions at UBS and Other Offshore Banks
A federal grand jury has indicted Drs. David Leon Fredrick and Patricia Lynn Hough alleging that they conspired to defraud the Internal Revenue Service (IRS) through a series of offshore accounts, using the funds buy homes in Florida, North Carolina and an airplane...
California Source Income Tax Rate Determined On Worldwide Income for Non-California Residents
A recent California State Board of Equalization (BOE) decision illustrates California's broad reach to tax non-residents. Specifically, the California Franchise Tax Board (FTB) was able to successfully argue that additional tax was due from a non-California resident...
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...
