Save as PDF RSS Feed Subscribe

Entries tagged “IRS”

IRS Voluntary Disclosure Practice - Internal Revenue Manual Updated Recently

Insight Melinda Fellner Bramwit Melinda Fellner Bramwit · December 10, 2020
You may know that the IRS Offshore Voluntary Disclosure Program (“OVDP”) closed, leaving taxpayers who did not fit within the confines of the streamlined programs with scant options for disclosure. As such, anyone who could not certify under penalties of perjury that their failure to report, disclose or pay tax was not

Continue Reading…

IRS Provides Several Items of Relief Benefiting Qualified Opportunity Funds and their Investors

Insight Debbie A. Klis Debbie A. Klis · June 05, 2020
On June 4, 2020, the Internal Revenue Service (IRS) released Notice 2020-39 that contains relief for several of the time-sensitive requirements for qualified opportunity funds (QOFs) and for taxpayers who invest capital gains in qualified opportunity zones (QOZs).  The QOZ program designates economically-distressed communities (more than

Continue Reading…

IRS guidance on virtual currency transactions

Insight Melinda Fellner Bramwit Melinda Fellner Bramwit · January 22, 2020
The last word taxpayers engaging in virtual currency transactions heard from the IRS was in 2014 in Notice 2014-21. Please review our commentary on the notice here. Now, five years later, the IRS has issued two new pieces of guidance for taxpayers in this area in the form of Revenue Ruling 2019-24 and a set of questions and answers on the

Continue Reading…

CLE Webinar - What’s New Pussycat? A Hot Update on IRS Disclosure Issues for 2017

Presentation provided by Rimon's Federal, State and International Tax Partner Melinda Fellner Bramwit  It has now been seven years since the launch of the first of the IRS offshore voluntary disclosure programs allowing taxpayers to come forward voluntarily to fix their unreported income issues and un-filed Fincen 114 (formerly "FBAR")

Continue Reading…

Key Highlights to Tax Professionals of New Offshore IRS Programs

Insight June 23, 2014
The Good News: The existing "Streamlined" procedure for non-resident, non-compliant taxpayers has been expanded significantly to permit many more non-filers to qualify for full abatement of penalties. Like the existing procedure, the new procedure (available here) requires taxpayers to file tax returns for the three most recent years and to

Continue Reading…

TAX ALERT - New IRS Amnesty for Offshore Accounts

Insight December 22, 2010

In his speech before the 23RD Annual Institute on Current Issues in International Taxation in Washington, DC on December 9, 2010, IRS Commissioner Douglas Shulman said that the IRS is “seriously considering” a new partial amnesty program for taxpayers who report secret offshore bank accounts.

Continue Reading…