By Phil Karter Is the IRS getting closer to ferreting out “quiet disclosures” by taxpayers who chose that route to address the problem of previously unreported offshore accounts rather than by participating in the Service's offshore voluntary disclosure program (OVDP)? That’s the conclusion of an increasing number of tax professionals and if taxpayers in this … Continue reading Are Quiet Disclosures of Offshore Accounts Becoming Even Riskier?
By Phil Karter In a recent TaxBlawg post, my colleague Jonathan Prokup discussed the IRS’ intention to begin requesting electronic files as part of taxpayer examinations so that it can analyze the “metadata” contained in those files. One of the concerns raised in the post, as announced in Chief Counsel Advice 201146017, was the possibility that … Continue reading IRS Records Retention Requirements In The Age Of Metadata
By Phil Karter As reported earlier this week in the tax press, the recently completed initial filing season for Schedule UTP produced at least one major surprise in the eyes of IRS officials, who had anticipated a much greater number of items listed on the average Schedule UTP than actually materialized. In fact, the IRS’s … Continue reading Musings in the Aftermath of the First Schedule UTP Filing Season
By Jonathan Prokup Over the weekend, a variety of Canadian news sources (see, e.g., the Financial Post and the Edmonton Journal) reported on anticipated guidance from the IRS, which would result in the waiver of penalties on certain U.S. citizens living in Canada for past failures to file Form TD F 90-22.1, commonly known as … Continue reading Good News For Bank Account Disclosures By U.S. Citizens Residing In Canada
By Jonathan Prokup During a webinar the other week regarding the impact of the Mayo Foundation decision on taxpayers, I discussed the effect of Mayo on taxpayers’ decisions to take positions that are contrary to IRS rules or regulations. Part of that discussion examined the 20-percent accuracy-related penalty that can be imposed on such positions … Continue reading Is Disclosure On Form 8275-R Required For A Position Contrary To A Revenue Ruling?
By Jonathan Prokup The Internal Revenue Service on Friday released the final version of the much-anticipated Schedule UTP (and accompanying instructions) as well as additional guidance about changes that had been made the schedule. At the same time, the IRS also announced an expansion of the Compliance Assurance Program (CAP) as well as some other … Continue reading So It Begins: The Final Schedule UTP Is Out
By Phil Karter In Tuesday’s confirmation hearings for Supreme Court nominee Elena Kagan, one topic on which there appeared to be agreement between the nominee and the panel was concern about the dwindling number of cases heard by the High Court. In response to questioning from Senator Arlen Specter, Kagan had no explanation for the … Continue reading The Tax Workpapers Conundrum – Will “Justice” Kagan Accept What Solicitor General Kagan Opposed?