If you received an unfavorable audit determination from the Internal Revenue Service (IRS), challenging the outcome of your audit will involve filing an appeal. In most cases, this starts with filing a “protest” with the appropriate IRS office. Before you file, however, you need to ensure that doing so is […]
Author: Lawrence Brown
The Internal Revenue Service (IRS) recently released its annual update to its Strategic Operating Plan. While several aspects of the annual update are notable, perhaps the most notable aspect is its focus on targeting high-income and high-net-worth taxpayers. In a News Release accompanying the release of the annual report, the […]
High-income and high-net-worth U.S. taxpayers who have assets held overseas have an obligation to report these assets to the U.S. Treasury Department. Specifically, taxpayers must report their offshore accounts to the Treasury’s Financial Crimes Enforcement Network (FinCEN), and they must report their “foreign financial assets” (which include offshore accounts) to […]
For high-income and high-net-worth U.S. taxpayers who are at risk of facing criminal prosecution due to willful tax law violations, making a voluntary disclosure to IRS Criminal Investigation (IRS CI) can facilitate a favorable resolution that avoids formal charges. But, making a voluntary disclosure presents its own risks—and it isn’t […]
Tax evasion is a serious federal crime. Individual taxpayers convicted of tax evasion can face up to a $100,000 fine and five years of federal imprisonment, while corporate entities can be fined up to $500,000. This raises an important question: What does it mean to “attempt to evade or defeat […]
Just like taxpayers, tax preparers have an obligation to comply with the Internal Revenue Code (IRC). Several provisions in the IRC speak specifically to the tax preparer’s role in preparing and submitting fraudulent returns—and tax preparers can face both civil and criminal penalties for aiding and abetting federal tax law […]
The IRS’s Voluntary Disclosure Practice (VDP) and its Streamlined Filing Compliance Procedures both provide ways for high-income and high-net-worth taxpayers to proactively resolve issues related to the disclosure (or non-disclosure) of their offshore assets. But, the VPD and Streamlined Filing Compliance Procedures are very different—each being subject to its own […]
The Voluntary Disclosure Practice (VDP) provides an avenue for high-income and high-net-worth taxpayers to resolve significant federal tax controversies without facing criminal prosecution. Administered by IRS Criminal Investigation (IRS CI), the VDP is a long-standing program that allows eligible taxpayers to mitigate their exposure and settle with the IRS—provided that […]
When seeking to close the tax gap through enforcement, the Internal Revenue Service (IRS) doesn’t solely target taxpayers who have underreported and underpaid their federal tax liability. It also targets those who facilitate tax evasion and tax fraud. Accountants, advisors and promoters can all face heavy-handed enforcement; and, when targeted […]
The Internal Revenue Code requires U.S. taxpayers to disclose certain transactions resulting in significant losses. The Internal Revenue Service (IRS) classifies these as “reportable transactions” due to their potential to serve as abusive tax shelters; and, as the IRS makes clear, “[e]ach taxpayer that has participated in a reportable transaction […]