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1. New streamlined procedures and changes to the Offshore Voluntary Disclosure Program are announced   WebExclusive

BY Sally P. Schreiber, J.D.
Just in time for the Foreign Account Tax Compliance Act (FATCA), which goes into effect July 1, the IRS announced changes to its streamlined filing compliance procedures and its Offshore Voluntary Disclosure Program (OVDP) designed to make it easier for taxpayers to comply with their obligations to report offshore assets and accounts (IR-2014-73).

2. IRS adopts “Taxpayer Bill of Rights”   WebExclusive

BY Paul Bonner
The IRS on Tuesday released a “Taxpayer Bill of Rights” intended to better communicate to taxpayers their existing statutory and administrative protections.Modeled after the U.S. Constitution’s Bill of Rights and a document of the Organisation for Economic Co-operation and Development, the 10 broad provisions were announced at a news conference at IRS headquarters in Washington by IRS Commissioner John Koskinen and National Taxpayer Advocate Nina Olson.

3. What tax preparers need to know about digital currency  

BY Andrew D. Gross, CPA (inactive), Ph.D., Jamie L. Hoelscher, Ph.D. and Brad J. Reed, CPA, Ph.D., CFE
Not long ago, few people had heard of bitcoins or digital currency. Now, digital currency routinely makes the headlines. Retailers such as Overstock.com, some sellers on online marketplace Etsy.com, and many other businesses now accept bitcoins as payment. By December 2013, it had been estimated that more than 1 million individuals had bitcoins, and about 10,000 people each owned more than $10,000 worth (Business Insider, Dec.

4. IRS must reconsider OIC  

BY Charles J. Reichert, CPA
The Tax Court holds that the IRS must fully consider an offer in compromise to promote effective tax administration.The Tax Court held that the IRS failed to adequately consider on public policy or equity grounds an offer in compromise (OIC) that a married couple had made, and it remanded the OIC to the IRS for proper consideration.Facts: Stacey and Timothy Bogart operated a construction company in the state of Washington for many years.

5. Practitioners suspended or disbarred from practice before the IRS can prepare tax returns   WebExclusive

BY Sally P. Schreiber, J.D.
The IRS has decided that, as a result of the recent decision preventing it from regulating unenrolled tax return preparers, disbarment or suspension from practice before the IRS cannot include a ban on tax return preparation or blocking an individual’s preparer tax identification number (PTIN). Therefore, the Service announced that certain tax return preparers who were sanctioned by having their PTINs blocked between Aug.

6. Tax owed on full sale price where taxpayer won’t provide cost basis information   WebExclusive

BY Sally P. Schreiber, J.D.
The Eleventh Circuit Court of Appeals upheld a deficiency notice of more than $5 million against a taxpayer who reported adjusted gross income of $22,921 and taxable income of $13,221 on his late-filed 2006 return (Hoang, No. 13-14398 (11th Cir. 5/2/14), aff’g T.C. Memo. 2013-127). Diep Hoang’s 2006 tax return was due Oct.

7. IRS announces two-year FATCA enforcement transition period   WebExclusive

BY Alistair M. Nevius, J.D.
Foreign financial institutions that make a good-faith effort to comply with the requirements of the Foreign Account Tax Compliance Act (FATCA) will benefit from lighter enforcement during 2014 and 2015, the IRS announced on Friday (Notice 2014-33). The IRS is treating those years as a “transition period” for the implementation of FATCA by withholding agents, foreign financial institutions (FFIs), and other entities with FATCA reporting and withholding responsibilities.

8. New rules for innocent spouse equitable relief  

BY Wei-Chih Chiang, DBA, Rachana Kalelkar, Ph.D. and and Xiaobo Dong, Ph.D.
The IRS Restructuring and Reform Act of 1998, P.L. 105-206, expanded innocent spouse relief into three categories: Sec. 6015(b) traditional innocent spouse relief; Sec. 6015(c) allocation of liability; and Sec. 6015(f) equitable relief. Since then, the IRS has received tens of thousands of innocent spouse relief requests annually.

9. Final FATCA rules are issued  

BY Sally P. Schreiber, J.D.
The IRS released regulations needed to implement the Foreign Account Tax Compliance Act (FATCA). FATCA, enacted as part of the Hiring Incentives to Restore Employment Act of 2010, P.L. 111-147, requires U.S. withholding agents to withhold tax on certain payments to foreign financial institutions (FFIs) that do not agree to report certain information to the IRS regarding their U.S.

10. Tenth Circuit throws out IRS summonses   WebExclusive

BY Sally P. Schreiber, J.D.
In a decision that creates a split from five other circuit courts, the Tenth Circuit Court of Appeals quashed IRS summonses that were issued after the 23-day period required under Sec. 7609(a)(1) (Jewell, Nos. 13-6069, 13-7038 (10th Cir. 4/28/14)). When the IRS issued four summonses to banks seeking records about nursing homes owned by Sam Jewell, it failed to notify Jewell 23 days before the records were to be examined.
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