In April the Justice Department filed a lawsuit that sought to force HSBC India to reveal the names of U.S. customers with secret accounts, and a U. S. District subsequently granted the IRS authority to issue John Doe Summons for the names of U. S. residents of Indian descent who have had NRE accounts (Non-resident External Rupee Accounts) at the bank.
Foreign Account Tax Compliance Act (FATCA) Explanation of Section 6038D Temporary and Proposed Regulations Custom Search _______________________________________________________________________________________________ The Foreign Account Tax Compliance Act, enacted in 2010, created new IRC Section 6038D and requires individuals to file a statement with their…
If a debt is canceled or forgiven, other than as a gift or bequest, the debtor generally must include the canceled amount in gross income for tax purposes. A debt includes any indebtedness for which the debtor is liable or which attaches to property the debtor holds.
January, 2012 Firm Tax Newsletter Custom Search
Under the Bank Secrecy Act, U.S. residents or a person in and doing business in the United States must file a report with the U.S. Treasury if he or she has a financial account in a foreign country with a value exceeding $10,000 at any time during the calendar year. Taxpayers comply with this law by noting the account on their tax return and by filing Form 90-22.1, the Foreign Bank and Financial Account Report (FBAR). Willfully failing to file an FBAR report can be punished under both civil and criminal law.
IRS Criminal Investigation (CI) is comprised of approximately 4,400 employees worldwide, approximately 2,600 of which are special agents whose investigative jurisdiction includes tax, money laundering and Bank Secrecy Act laws. While other federal agencies also have investigative jurisdiction for money laundering and some bank secrecy act violations, IRS is the only federal agency that can investigate potential criminal violations of the Internal Revenue Code.
An overemphasis on cycle time creates incentives for IRS employees to take actions quickly, even where doing so produces inaccurate results or delays the final resolution of problems.
Custom Search Arnstein & Lehr Chicago Partner Robert E. McKenzie recently authored a piece titled, "IRS and Offshore Accounts." It discusses the IRS' new 2011 Voluntary Disclosure Initiative (OVDI) for taxpayers to disclose their unreported offshore accounts. To read "IRS…
Robert McKenzie was recognized in an article in the April/May 2009 edition of CPA Magazine entitled the “Top 40 Tax Advisors to Know During a Recession.” State society and national association of CPAs and accountants nominated the candidates. Each candidate was then asked to submit words of advice about tax planning during a recession.
PURCHASE REPRESENTATION BEFORE THE UNITED STATES TAX COURT FROM THOMSON WEST REPRESENTATION BEFORE THE UNITED STATES TAX COURT By: - Robert E. McKenzie and Jeffry J. Erney and Thomas J. Callahan and Gregory J. Gawlik Custom Search This…