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IRS Audits Focused Upon OVDP Declines and Withdrawls

A new IRS Large Business & International (LB&I) campaign targets US taxpayers for IRS audits focused upon OVDP declines and withdrawls from the FBAR related program.  Once the IRS implemented FATCA based regulations and the associated Foreign Bank Account Reporting (FBAR) requirements US taxpayers were required to disclose all offshore...

IRS Focusing on Transfer Pricing and Offshore Earnings says Wall Street Journal

In a recent article the Wall Street Journal warned that the IRS had released information about 13 "campaigns" to target high-value tax returns for IRS audit.  The IRS intends to focus upon  and international businesses transfer pricing and offshore earnings and the compliance with IRS FBAR reporting and offshore account...

Record Number Renounce Their US Citizenship in 2016 Due to US Taxation of Worldwide Income

The US Treasury Department published the latest list of those who renounced their US citizenship in 2016.  The recent spike in renounced citizenships has been tied to US taxation of worldwide income for all US residents and taxpayers.  5,411 individuals renounced their US citizenship in 2016, and while this may...

IRS Launches New Campaigns to Focus Vertical Market Expertise on Tax Revenue Generation

The IRS launches new campaigns to focus vertical market expertise on tax revenue generation and compliance.  Each "campaign" aligns internal IRS expertise on specific issues with the goal of "focused examination" (read: audit) on targeted matters.  What are the 13 business related IRS audit campaigns and how will they affect...

Updates on Offshore Investments and IRS FBAR Reporting Requirements

The world is still unpacking the impact of FATCA and the IRS' intent to track offshore bank accounts, investments and corporations.  The result is continuing pressure on offshore investments and IRS FBAR reporting requirements including PFIC tax calculations and the continuing expansion of 50% penalties on specific institutions identified by...