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December 23, 2022

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Correcting Offshore Account Disclosure Violations—Should You Submit a Streamlined Filing or Voluntary Disclosure in 2023?

U.S. taxpayers who own offshore accounts and certain other foreign financial assets have an obligation to disclose these assets to the Internal Revenue Service (IRS)—provided that their value exceeds the IRS’ relatively modest reporting thresholds. Depending on the nature of a taxpayer’s foreign financial assets, this may entail two separate […]

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International tax issues

November 29, 2022

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IRS to step up examinations of potentially abusive micro-captive insurance schemes

The IRS made a large investment in personnel to accelerate investigation of potential abuses of micro-captive insurance transactions.  Since 2014, the IRS has put micro-captive insurance arrangements under a microscope to uncover taxpayers and taxpaying entities that may be abusing associated tax benefits. We provided an article in 2019 about IRS settlement […]

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Important Trends at IRS