1.10 While the process is not mandated by statute, the Service has, for over 60 years, provided taxpayers with an administrative alternative to litigating their tax disputes in court [Reg. § 601.106]. Now commonly referred to as Appeals, this administrative branch of the IRS generally has the final power and authority of the IRS to determine audit liabilities of taxpayers
Tax season is upon us, and Arnstein & Lehr’s Chicago partner Robert McKenzie helps shed some light on new rules for offshore foreign account filing. The Foreign Account Tax Compliance Act’s (FATCA) was passed in 2010 after Congress discovered the large number of Americans hiding their money in offshore accounts. The law states that every year, all foreign banks, worldwide, must send an information document on all Americans to the IRS. If a bank does not comply, the IRS can require American banks to withhold 30% of transactions between them. Listen to Bob McKenzie’s audio commentary here.