Rimon

Entries tagged “irs”

IRS Voluntary Disclosure Practice – Internal Revenue Manual Updated Recently

insights IRS Voluntary Disclosure Practice – Internal Revenue Manual Updated Recently Melinda Fellner · December 10, 2020

You may know that the IRS Offshore Voluntary Disclosure Program (“OVDP”) closed, leaving taxpayers who did not fit within the confines of the streamlined programs with scant options for disclosure. As such, anyone who could not certify under penalties of perjury that their failure to report, disclose or pay tax was not willful, was left twisting in the…

Continue Reading…

IRS Provides Several Items of Relief Benefiting Qualified Opportunity Funds and their Investors

insights IRS Provides Several Items of Relief Benefiting Qualified Opportunity Funds and their Investors Debbie A. Klis · June 5, 2020

On June 4, 2020, the Internal Revenue Service (IRS) released Notice 2020-39 that contains relief for several of the time-sensitive requirements for qualified opportunity funds (QOFs) and for taxpayers who invest capital gains in qualified opportunity zones (QOZs).  The QOZ program designates economically-distressed communities (more than 8,700 QOZs nationwide) and encourages private investment and economic growth…

Continue Reading…

IRS guidance on virtual currency transactions

insights IRS guidance on virtual currency transactions Melinda Fellner · January 22, 2020

The last word taxpayers engaging in virtual currency transactions heard from the IRS was in 2014 in Notice 2014-21. Please review our commentary on the notice here. Now, five years later, the IRS has issued two new pieces of guidance for taxpayers in this area in the form of Revenue Ruling 2019-24 and a set of questions…

Continue Reading…

CLE Webinar – What’s New Pussycat? A Hot Update on IRS Disclosure Issues for 2017

events CLE Webinar – What’s New Pussycat? A Hot Update on IRS Disclosure Issues for 2017 Melinda Fellner · November 16, 2016

Presentation provided by Rimon’s Federal, State and International Tax Partner Melinda Fellner It has now been seven years since the launch of the first of the IRS offshore voluntary disclosure programs allowing taxpayers to come forward voluntarily to fix their unreported income issues and un-filed Fincen 114 (formerly “FBAR”) issues. Melinda will review the present…

Continue Reading…

Key Highlights to Tax Professionals of New Offshore IRS Programs

insights June 23, 2014

The Good News: The existing “Streamlined” procedure for non-resident, non-compliant taxpayers has been expanded significantly to permit many more non-filers to qualify for full abatement of penalties. Like the existing procedure, the new procedure (available here) requires taxpayers to file tax returns for the three most recent years and to file foreign bank account reports (FBARs) for…

Continue Reading…

TAX ALERT – New IRS Amnesty for Offshore Accounts

insights December 22, 2010

In his speech before the 23RD Annual Institute on Current Issues in International Taxation in Washington, DC on December 9, 2010, IRS Commissioner Douglas Shulman said that the IRS is “seriously considering” a new partial amnesty program for taxpayers who report secret offshore bank accounts. Shulman said that the IRS may repeat a voluntary disclosure…

Continue Reading…