Procedural Requirements for Imposition of Penalties and Additions to Tax
The Internal Revenue Service Restructuring Act required that each notice imposing a penalty include the name of the penalty, the Code section imposing the penalty, and a computation of the penalty. The Act also requires the specific approval of IRS management to assess all non computer generated penalties unless excepted. This provision does not apply to failure to file penalties, failure to pay penalties, or to penalties for failure to pay estimated tax.
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.