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Sometimes a taxpayer who enters 2012 OVDP also has undisclosed domestic tax liability and the question arises with respect to how to handle this additional liability. As was the case with the 2009 OVDP and the 2011 OVDI, the 2012 OVDP is available to taxpayers who have both offshore and domestic issues to disclose. The […]
One of the most dramatic effects of the American Taxpayer Relief Act of 2012 (ATRA) was felt in the area of gift and estate taxes. Pre-ATRA Situation In 2012, the estate and gift tax exemptions, indexed for inflation, were set at $5,120,000 each (up from $5,000,000 in 2011). Moreover, in 2012, the surviving spouse could […]
In an earlier article, I discussed the general Offshore Voluntary Disclosure Program eligibility requirements now closed, particularly those spelled out in the Internal Revenue Manual (IRM). In this essay, I would like to provide certain examples of when a taxpayer’s disclosure fails to meet IRM 9.5.11.9 requirements. Note, these examples are not specific to offshore […]
If a taxpayer is about to conduct a voluntary disclosure of his offshore accounts, a question arises about his eligibility to do so in a situation where the IRS already served a “John Doe” summons or made a treaty request seeking information that may identify a taxpayer as holding an undisclosed foreign account or undisclosed […]
In its Revenue Procedure 2013-15, the IRS stated that, for the 2013 taxable year, the $2,500 maximum deduction for interest paid on qualified education loans under IRC § 221 begins to phase out under IRC § 221(b)(2)(B) for taxpayers with modified adjusted gross income in excess of $60,000 ($125,000 for joint returns). It is completely […]