The Internal Revenue Service Restructuring and Reform Act of 1998 requires the Secretary to grant an installment agreement, at the taxpayer’s option, if:
• the liability is $10,000, or less (excluding penalties and interest);
• within the previous 5 years, the taxpayer has not failed to file or to pay, nor entered an installment agreement under this provision; [Act § 3467; IRC § 6159)
Taxpayers with offshore bank accounts might be in trouble. The Foreign Account Tax Compliance Act (FATCA) went into effect on July 1 requires that foreign banks report to the IRS about the accounts of U.S. taxpayers. As a result, more than 100 Swiss banks are handing over information on potential U.S. tax evaders.