IRS filing season to commence January 28, 2019

After more than two weeks of hiatus, we have news that the IRS will commence processing 2018 tax returns on January 28, 2019. The IRS, the revenue agency of the US government, currently has 90% of its workforce on leave without pay. In a departure from the now-expired...

Internal Revenue Service partial shutdown

The IRS has a contingency plan in place, the Lapsed Appropriations Contingency Plan (‘contingency plan’), in preparation for the US government shutdown which is currently occurring. The 120-page document details what areas of the IRS will shut down, and...

First prosecution under FATCA – Landmark Case

Eight years after the Foreign Account Tax Compliance Act (FATCA) was enacted as part of the 2010 Hire Act, the Eastern District of New York has prosecuted an executive of Loyal Bank for wilfully circumventing the reporting requirements of FATCA.   The executive, in...

Foreign Trusts Reporting – IRS To Target

United States citizens and other residents of the United States with foreign trusts requiring the annual filing of such forms as Form 3520 and Form 3520-a have been selected by the IRS Large Business and International division (LB&I) for six compliance campaigns....

IRS Ends Offshore Voluntary Disclosure Program

The Internal Revenue Service has announced the end of the Offshore Voluntary Disclosure Program (OVDP).  The deadline for full and final submissions has been announced as 28 September 2018. The OVDP program has been around in one form or another since 2009. It is...

US Passport Revocation – Unpaid Taxes

The 2015 enactment of the Fixing America’s Surface Transportation (FAST) Act gave the Internal Revenue Service the authority to start revoking or denying passport applications of taxpayers with ‘seriously delinquent tax debts’.   ‘Seriously...