Washington D.C. Tax Law Blog

The IRS’s stepped-up enforcement campaign on offshore account disclosure has been going on for years now. Combined with the rollout of the Foreign Account Tax Compliance Act, it has put great pressure on taxpayers with offshore holding as well as foreign financial institutions. Faced with possible criminal penalties, many taxpayers have chosen to participate in […]

Glen Frost is advocating for a same country exemption from FATCA reporting for citizens living abroad: https://www.internationalinvestment.net/products/american-expat-group-calls-country-fatca-exemption/ Here is the text of the letter from American Citizens Abroad to the Deputy Assistant Secretary for International Tax Affairs Robert Stack: August 10, 2016 The Honorable Robert B. Stack Deputy Assistant Secretary for International Tax Affairs United […]

Let’s continue the discussion we started last week of IRS whistleblower awards. Last week, we noted that a recent Tax Court ruling has broadened to scope of awards to be based not only a percentage of unpaid taxes, but also on criminal fines and civil forfeiture. In this part of the post, we will explain […]

The IRS operates a whistleblower program by which individuals who tip off the government about tax evasion can potentially receive monetary awards. Critics sometimes contend that whistleblowers have to wait too long for the IRS to act on applications for awards. But when large amounts of unpaid taxes are involved, the awards to whistleblowers can […]

Let’s continue the discussion we began last week about the creation of a common reporting standard (CRS) for revenue agencies around the world to exchange information about tax compliance. The CRS won’t take formal effect until September 2017. But more than 100 counties have already agreed to participate. In this part of the post, we […]

The international tax landscape has changed radically in recent years. The IRS enforcement crackdown on offshore account reporting is only one aspect of this. Also looming large of course is passage by Congress of the Foreign Account Tax Compliance Act (FATCA) and the intergovernmental agreements worked out by the Treasury Department to enforce it. But […]

In part one of this post, we began discussing the challenges you can face as a business owner if you fall behind on your payroll taxes. If your business runs into cashflow problems, it can be tempting to dip into the money you withheld from employees’ wage for payroll taxes. This may seem like merely […]

“I can resist everything except temptation,” quipped the flamboyant Victorian poet Oscar Wilde. To be sure, you may feel you have more ability to resist your particular temptations than Wilde had to resist his. But if you are a business owner who is tempted to dip into payroll taxes withheld from employees to cover cashflow […]

A few years ago, Congress got the idea that businesses could be more accurate in reporting all of their income. The concern was that there was a significant gap between taxable income and income reported on tax returns. To respond to this concern, Congress added a provision to the tax code to require credit-card companies […]

One by one, the giants of Swiss banking have fallen. They have been forced to submit to the long-running American enforcement crackdown on offshore accounts. That crackdown is not only long-running; the standards for compliance have been stepped up since Congress passed the Foreign Account Tax Compliance Act (FATCA) in 2010. The first Swiss giant […]