With the Federal government searching for much-needed revenues, it is very likely that the IRS will be watching much more closely for unpaid payroll taxes, as it has been in recent years.  This article will explain the purpose of Form 941 and when it needs to be filed.  In a future article, we will cover [...]

Some taxpayers may be tempted, especially in situations involving related parties, to arbitrarily shift the source of income or allocation of deductions, in order to avoid or lessen taxes.  Congress, however, enacted IRC Section 482 to give the IRS wide power to prevent such actions.  This article will give a brief overview of some aspects [...]

This article offers an important strategic perspective on the foreign financial accounts disclosure in the year 2012. In particular, it appears that, this year, U.S. taxpayers who have not fully disclosed their foreign financial accounts and foreign assets should make the urgent decision to bring their tax affairs into full compliance. Three Trends Greatly Enhanced [...]

In a previous article, we covered the basics of the IRS Form 5472. In this article we will explain the penalties that may apply for failure to comply with the form’s requirements. Main Failure to File and Failure to Maintain Records Penalties If a corporation fails to timely file the required Form 5472, a $10,000 [...]

In a previous article, I already discussed some of the major differences between 501(c)(3) and 501(c)(6) organizations. However, this discussion was limited to characteristics of these organizations as opposed to dynamic developments that these organizations may experience during their existence. While most of these organizations tend to be stable once a particular type of tax-exempt [...]

The announcement by the IRS of the opening of the new Offshore Voluntary Disclosure Program (OVDP) on January 9, 2012 came as a surprise to most tax practitioners, especially since the 2011 OVDI just ended on September 9, 2011. Yet, if one analyzes the number of new developments in international tax compliance over the past [...]

If you find yourself in legal trouble as a result of international tax non-compliance, it is very important for you to retain the voluntary disclosure attorney who suits your situations best. It is highly imprudent for you to represent yourself in such cases – the issues are usually highly complex, the penalties can be extremely [...]

The new IRS Form 8938 is not just another tax form that a taxpayer needs to file. Its reach and impact on taxpayer compliance and IRS ability to verify it are far more profound. Yet, while the addition of Form 8938 to the long list of international tax compliance forms has created a burst of [...]

The focus of this article is to provide some basic information on the IRS Form 5472, an Information Return of a 25% Foreign-Owned U.S. Corporation or a Foreign Corporation Engaged in a U.S. Trade or Business. The purpose of Form 5472 is to provide information required by the IRS when “reportable transactions” occur during the [...]

As the United States government has increasingly searched for needed revenues, and some members of Congress have called for higher taxes on hedge fund managers and various other new tax proposals have been suggested.  One such proposal is the “Enterprise Value Tax”, which passed in the House of Representatives in 2010 (as part of “H.R. [...]