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Category Archives: From Live Blog

Unique Identification Number Allows IRS to Identify Foreign Entities

A new IRS Webpage on how to file tax forms related to foreign interests using a unique reference identification number (URI) is designed to allow the Internal Revenue Service to more easily identify a taxpayer's foreign entities and compare their activities, or lack of activities, from year to year.

Beginning with U.S. federal tax returns filed for the 2012 tax year, taxpayers who file a Form 5471 (Information Return of U.S. Persons With Respect to Certain Foreign Corporations), a Form 8858 (Information Return of U.S. Persons With Respect to Foreign Disregarded Entities), or Form 8865 (Return of U.S. Persons With Respect to Certain Foreign Partnerships), must provide the URI or employer identification number for all foreign entities reported on the forms.

Implementation of URIs could pose varied obstacles for taxpayers who are unprepared.

Read more at: Tax Times blog

FinCEN postpones mandatory FBAR e-filing

The IRS does not permit electronic filing of US income tax returns for preparers living outside the US. It remains to be seen if they will apply the same rule to FBAR forms. For 2011 FBAR forms should be manually filed as in the past. Failure to file FBAR forms on time may result in substantial penalties.

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Read more at: Tax Times blog

IRS Criminal Investigations Unit obtains 94 Percent Conviction Rate.

According to Rick Raven, deputy chief of IRS investigations, the cases that IRS's criminal investigations unit sends to the tax division have ended up in a 94 percent conviction rate, making it the highest rate of conviction in law enforcement.

 
Offshore tax evasion is taking up a lot of the unit's time, Raven says. More international banks are under investigation than at any time in the history of IRS Criminal Investigation, he says. More than 300 investigations of individuals with ties to international banks are under way, with IRS looking for hidden money overseas.
 
Criminal Investigation (CI) investigates  potential criminal violations of the Internal Revenue Code and related financial crimes in a manner that fosters confidence in the tax system and compliance with the law.
 
IRS Criminal Investigation (CI) is comprised of approximately 4,100 employees worldwide, approximately 2,700 of whom are special agents whose investigative jurisdiction includes tax, money laundering and Bank Secrecy Act laws. While other federal agencies also have investigative jurisdiction for money laundering and some bank secrecy act violations, IRS is the only federal agency that can investigate potential criminal violations of the Internal Revenue Code.
 
The Criminal Investigation strategic plan is comprised of three interdependent programs: Legal Source Tax Crimes; Illegal Source Financial Crimes; and Narcotics Related and Counterterrorism Financial Crimes. These three programs are mutually supportive and encourage utilization of all statutes within CI’s jurisdiction, the grand jury process and enforcement techniques to combat tax, money laundering and currency crime violations. CI must investigate and assist in the prosecution of those significant financial investigations that will generate the maximum deterrent effect, enhance voluntary compliance and promote public confidence in the tax system.

Read more at: Tax Times blog

Even Rich Heirs Deserve A Fair Shake From The IRS –

The IRS wants to tax the Sonnabend estate on a Rauschenberg that can't legally be sold, on the grounds that law-abiding heirs can always sell on the black market. Huh?

It appears that Sonnabend’s heirs sold off works by Jeff Koons, Roy Lichtenstein, Andy Warhol and Cy Twombly to pay estate taxes of $331 million to Uncle Sam and $140 million to New York State.

But they couldn’t even consider selling what might have been the most famous piece in her collection — “Canyon” by Robert Rauschenberg— because the collage contains a stuffed bald eagle and selling it would be a criminal offense, punishable by a year in federal pen.

Given that restriction, the Sonnabend estate tax return (and three different appraisers the estate hired) valued the work at $0. The IRS says it is worth $65 million and is demanding an additional $29 million in tax and an $11.7 million “gross valuation misstatement” penalty from the estate.

To read more go to:

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Read more at: Tax Times blog

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