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Author: Lawrence Brown

What Are the Concerns for Taxpayers Considering a Streamlined Filing?

The Internal Revenue Service’s (IRS) streamlined filing compliance procedures provide a way for U.S. taxpayers to mitigate the consequences of failing to disclose their foreign financial assets. Taxpayers who qualify to submit a streamlined filing are not subject to failure-to-file, failure-to-pay or accuracy-related penalties and instead pay a five-percent “miscellaneous […]

FATCA

What to Know About IRS CI’s Voluntary Disclosure Practice

U.S. taxpayers that have failed to meet their filing and payment obligations have various options for resolving these “tax controversies” with the Internal Revenue Service (IRS). However, the specific options that are available in any particular case depend on the circumstances involved. For example, while IRS Criminal Investigation’s (IRS CI) […]

IRS

What Are the IRS’ “Listed Transactions?”

Through its rulemaking authority, the Internal Revenue Service (IRS) has identified several types of transactions as “listed transactions.” As the IRS explains, a listed transaction is any transaction that is, “the same as, or substantially similar to, one that the IRS has determined to be a tax avoidance transaction and […]

Audits