Circular 230 final regs. make ubiquitous email disclaimer no longer necessary. The IRS issued final regulations under Circular 230, Regulations Governing Practice Before the Internal Revenue Service (31 C.F.R. Part 10), on the rules for practitioners to provide written tax advice and certain other related provisions, adopting the proposed regulations
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TOPICS / TAX
IRS practice & procedure
Expanded OVDP a chance to reduce penalties
The new information-reporting requirements of the Foreign Account Tax Compliance Act (FATCA), P.L. 111-147, took effect on July 1. Among other things, FATCA requires foreign financial institutions (FFIs) to report on their accounts held by U.S. taxpayers. More than 77,000 FFIs signed on and acquired approved status in the initial
New IRS appeals process starts Sept. 2
Starting Sept. 2, the IRS Office of Appeals is changing the way it handles appeals to examination decisions. Under the new Appeals Judicial Approach and Culture (AJAC) project, appeals officers are “no longer going to be examiners or investigators,” Appeals Team Manager Philip A. Oyoto told preparers at the IRS
SEC will scrutinize municipal advisers’ rules compliance
A new SEC examination initiative will scrutinize municipal advisers’ compliance with new rules and regulations that are under implementation. The SEC announced Tuesday that its Office of Compliance Inspections and Examinations (OCIE) will examine a significant percentage of municipal advisers for compliance. “The municipal adviser examination initiative will focus on
Whistleblower final rules expand definition of collected proceeds
Comprehensive final regulations issued Thursday provide rules for whistleblower awards under Secs. 7623(a) and (b), as well as rules governing the disclosure of return information under Sec. 6103(h) to pursue these claims (T.D. 9687). The regulations provide the rules for submitting information to the IRS, define key terms, provide rules
New streamlined procedures and changes to the Offshore Voluntary Disclosure Program are announced
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
IRS adopts “Taxpayer Bill of Rights”
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
What tax preparers need to know about digital currency
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
IRS must reconsider OIC
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
Practitioners suspended or disbarred from practice before the IRS can prepare tax returns
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
Tax owed on full sale price where taxpayer won’t provide cost basis information
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
IRS announces two-year FATCA enforcement transition period
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
New rules for innocent spouse equitable relief
A new, more comprehensive revenue procedure may spell equitable relief for many more taxpayers.
Final FATCA rules are issued
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
Tenth Circuit throws out IRS summonses
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
Taxpayers must reveal tax shelter opinion letters despite attorney-client privilege
By attempting to establish good-faith and state-of-mind defenses, taxpayers put their legal knowledge and understanding into contention, and therefore they waived attorney-client privilege, the Tax Court held on Wednesday (Ad Investment 2000 Fund LLC, 142 T.C. No. 13 (2014)). As a result, the court will order the taxpayers to produce
Critical lessons from the Peco Foods case
The Tax Court’s Peco Foods ruling imparts several critical tax lessons for all taxpayers in an acquisition mode, regardless of whether they plan to pursue a cost-segregation study.
IRS clarifies: Electronic signatures permitted for Form 8879
Correcting an oversight, the IRS on Thursday updated the online version of Publication 1345, Handbook for Authorized IRS e-File Providers of Individual Income Tax Returns (rev. 3/20/14), to clarify that electronic signatures are permitted for Form 8879, IRS e-File Signature Authorization, as well as Form 8878, IRS e-file Signature Authorization
IRS expands use of electronic signatures
With the updated version of IRS Publication 1345, Handbook for Authorized IRS e-File Providers of Individual Income Tax Returns (rev. 3/11/14), the IRS provides new methods for taxpayers to electronically sign Form 8878, IRS e-file Signature Authorization for Form 4868 and Form 2350, the e-file signature authorization form. Taxpayers can
Take steps to meet the EITC due-diligence requirements
The IRS is scrutinizing returns that claim the earned income tax credit (EITC) and paying attention to return preparers who it suspects are filing inaccurate EITC claims. New due-diligence rules require practitioners to document more information and report it to the IRS with every return filed.
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