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 Jonathan Prokup From time to time, we receive questions from readers about current topics on their minds. One of our readers wrote earlier this week to ask about an article from Monday’s Tax Notes – 2011 Brings New Return Obligation for Corporate Actions Affecting Basis, by Amy Elliott. The article discussed the newly effective … Continue reading New Section 6045B: Reporting Not Required For Corporate Subsidiaries
By Dustin Covello As we’ve discussed previously at the TaxBlawg, a minor provision of the Patient Protection and Affordable Care Act – Section 9006, which dramatically expands the requirements for reporting payments on Form 1099 – has become a hot-button issue in Congress. Prior to the law, Form 1099 reporting was not required for payments … Continue reading Senate Fixes An Onerous Reporting Requirement With An Onerous Reporting Requirement?
By Jonathan Prokup Although death and taxes might, according to Benjamin Franklin, be the only certainties in this world, Congress is surely striving to add another - that is, the certainty of uncertainty. Congress, it seems, is committed to keeping taxpayers in as much doubt as possible for as long as possible about the status … Continue reading Certain Uncertainty: Congress Juggles Tax Proposals
By George W. Connelly As my readers know, I focus my practice on representing people who have “misunderstandings” with the Internal Revenue Service. I can’t count the number of clients who have made a comment along the lines of “get me Geithner’s deal” since it came to light that he had some significant and frankly embarrassing … Continue reading What Would Happen If A Taxpayer Asks The IRS For The Same “Deal” That Timothy Geithner Got?