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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 (now closed) 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 […]