Yearly Archives: 2011

New regulations provide that a evidence of a postmark is not sufficient to prove delivery. ( T.D. 9543, 76 Fed. Reg. 52561 (8/23/11), amending Regs. §301.7502-1, by revising paragraphs (b)(2) and (e) and adding paragraphs (c)(3) and (g)(4)).

WASHINGTON –The Internal Revenue Service’s (IRS) Criminal Investigation (CI) division surpassed its goals for Fiscal Year (FY) 2010, according to a new report publicly released by the Treasury Inspector General for Tax Administration (TIGTA).

CI is primarily dedicated to developing and investigating legal source tax cases, which are crimes involving legal industries and occupations and legally earned income. The prosecution of these cases is key to supporting the IRS’s overall compliance goals, enhancing voluntary compliance with the tax laws, and promoting fairness and equity in the tax system. The overall objective of TIGTA’s review was to provide a statistical portrayal with trend analyses of CI’s enforcement activities for Fiscal Years 2006 through 2010.

For more information go to http://www.forbes.com/sites/peterjreilly/2011/08/29/whatcha-gonna-do-when-they-come-for-you-irs-cid-stepping-up-its-act/

The IRS stated on August 26 and further clarified on August 29 that due to the potential impact of Hurricane Irene it has extended the due date for its 2011 Offshore Voluntary Disclosure Initiative (OVDI) requests and several other required informational returns from August 31, 2011 until September 9, 2011.

• Identifying information must be submitted to the Criminal Investigation office. This includes name, address, date of birth, and social security number and as much of the other information requested in the Offshore Voluntary Disclosures Letter as possible. This information must be sent to:

  Offshore Voluntary Disclosure Coordinator
  600 Arch Street, Room 6404
  Philadelphia, PA 19106

• Send a request for a 90-day extension for submitting the complete voluntary disclosure package of information to the Austin campus. This request must be sent to:

  Internal Revenue Service
  3651 S. I H 35 Stop 4301 AUSC
  Austin, TX 78741
  ATTN: 2011 Offshore Voluntary Disclosure Initiative

The Swiss government has put forward a clarification of the new U.S.-Swiss double taxation tax treaty, which may help resolve a dispute between the two countries over allegations that Switzerland’s second largest bank helped its U.S. clients evade taxes.

A spokesman for the Swiss Federal Tax Administration, Mario Tuor, confirmed Aug. 29 that the Federal Council, the government’s executive arm, sent a memorandum dated Aug. 8 outlining an interpretation of administrative assistance under the treaty. That interpretation may make it easier for the U.S. Internal Revenue Service to seek out information on undeclared accounts of U.S. clients with the Swiss bank, Credit Suisse. The memorandum, forwarded to the foreign affairs committee of the Swiss parliament’s upper house, contains a clarification of the tax agreement by the Federal Council.

 It was understood the memorandum makes reference to the draft of an undertaking by the Swiss government to hand over a list of U.S. clients with Credit Suisse accounts to U.S. tax authorities – just as the Swiss government agreed to do in 2009 in regards to U.S. demands for information on undeclared accounts of U.S. clients with UBS, Switzerland’s largest bank.