Charitable Contributions--Do you know where your 170(f)(8) letter is ?
In order to be entitled to a deduction, for a charitable contribution of $250 or more, section 170(f)(8) of the Internal Revenue Code requires a taxpayer to have a Contemporaneous Written...
View ArticleU.S. Taxpayers Living Abroad - Reduced Penalties To Come Clean
In a bid to encourage U.S. taxpayers living abroad to file U.S. tax returns and FBARs, the IRS has significantly reduced the civil penalties associated with the 2011 Offshore Voluntary Disclosure...
View ArticleIRS May Pursue Gift Tax from Donors to Some Politically Active Organizations
Organizations formed to support particular political candidates often achieve favorable tax status as political action committees (“PACs”) and those formed to focus on particular causes can be formed...
View ArticleColorado Enacts Tax Amnesty Program
Colorado's recently enacted Taxpayer Amnesty program is provides a one-time opportunity for non-compliant taxpayers to file overdue returns and become compliant. The program covers many types of tax...
View ArticleIRS Grants Additional Time To File FBARs
Today, the IRS announced an extension until November 1, 2011 for taxpayers who did not file TD F 90-22.1 (FBARs) forms in prior years. For those taxpayers who only had signatory authority over a...
View ArticleCareful Attention to Offshore Voluntary Disclosure Cases
Baker Hostetler’s lawyers have handled hundreds of voluntary disclosures through the 2009 and 2011 Offshore Voluntary Disclosure Programs (OVDI). Recently, the IRS has announced a third OVDI, this...
View ArticleIRS Includes Hiding Offshore Income on List of Dirty Dozen Tax Scams for 2012
See IRS Video posted here: http://youtu.be/10D1XqVmIW0 IRS News Release is posted here: http://www.irs.gov/newsroom/article/0,,id=254383,00.html
View ArticleNew Foreign Asset Reporting Requirements for 2011 Returns
The HIRE Act of 2010 enacted Section 6038D which requires single taxpayers to report ownership of specified foreign financial assets which in aggregate exceed $50,000 on new Form 8938, which is filed...
View ArticleColorado Court of Appeals Releases Significant Decision Affecting Colorado...
On March 15, the Colorado Court of Appeals issued its much anticipated decision in Kowalchik v. Brohl. The Court determined that transferees who purchased conservation easement credits from donors of...
View ArticleIRS Clarifies Form 8938 Reporting
The IRS has added nine new questions and answers addressing the filing requirements for Form 8938, Statement of Foreign Financial Assets. These new Q&A address a variety of issues including...
View ArticleU.S. Treasury Releases Joint Statements with Switzerland and Japan Announcing...
The U.S. Treasury released joint statements with Switzerland and Japan announcing their “mutual intent to pursue a framework for intergovernmental cooperation to facilitate the implementation of the...
View ArticleIRS Issues Updated Guidance for 2012 Offshore Voluntary Disclosure Program
On June 26, 2012, the Internal Revenue Service (“IRS”) released new FAQ’s on the current Offshore Voluntary Disclosure Program (“OVDP”) . The IRS opened the current OVDP on January 9, 2012, but, other...
View ArticleGAO recommends IRS Step Up Enforcement Measures for Dentists, Doctors and...
In a report issued July 27, 2012, the GAO recommended that the IRS “explore opportunities to enhance collection of unpaid taxes from Medicaid providers, including the use of continuous levies.” The...
View ArticleIRS and DOJ Losing Patience with Taxpayers with Undisclosed Foreign Accounts
The assistant US attorney general for the Tax Division, Kathryn Keneally, recently indicated that the window for avoiding criminal prosecution related to undeclared foreign accounts may be closing...
View ArticleThe 2012 FBAR Filing Deadline is June 30, 2013
U.S. taxpayers with foreign accounts whose aggregate value exceeded $10,000 at any time during 2012 must file Treasury Department Form TD F 90-22.1 (Report of Foreign Bank and Financial Accounts) with...
View ArticleTaxpayer Advocate Continues to Criticize Offshore Voluntary Disclosure Programs
In an update to her December 2012 report, the Taxpayer Advocate has noted that the IRS still has not provided reasonable options for “benign actors”, or taxpayers who inadvertently violated the rules...
View ArticleTax Court Rules that IRS Too Aggressive in Applying Qualified Appraisal and...
In Friedberg v. Comm’r, T.C. Memo 2011-238, the Tax Court granted summary judgment for the IRS, holding that an appraisal used to substantiate a facade easement donation amount was not a qualified...
View ArticleWho will be home at the IRS if there is a Government Shutdown?
Treasury released its contingency plan to address a pending government shutdown. So, who will be home at the IRS? Here is what we know: IRS will: continue automated collections activities continue...
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