The Treasury Department and the IRS released their 2017-2018 Priority Guidance Plan, which prioritizes various tax issues that should be addressed through regulations, revenue rulings, revenue procedures, notices, and other
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Fox Rothschild LLP
IRS Takes Measures to Curb Business Identity Theft
The IRS is putting an increased emphasis on identity theft protections for business returns as a result of an increase in fraudulent business tax returns in recent years. The IRS…
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Swiss-Domiciled Company Denied Treaty Benefits For Treaty Shopping
Statutory Background
When a foreign corporation receives dividends from U.S. sources, the income is generally subject to tax at 30%. To avoid double taxation and encourage cross-border investments, the U.S.
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FinCEN Provides FBAR Relief to Victims of Hurricane Harvey
The Financial Crimes Enforcement Network (FinCEN) announced today that Hurricane Harvey victims in the affected areas of Texas have until January 31, 2018 to file their 2016 FBARs (that would…
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Tax Relief for Victims of Hurricane Harvey
The President has declared a major disaster in the State of Texas. The declaration permits the IRS to postpone certain deadlines for taxpayers who reside or have a business in…
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Three More Countries Will Now Provide IRS Information on Bank Interest paid to Nonresident Aliens
The IRS recently released Revenue Procedure 2017-31 which adds Belgium, Columbia and Portugal to the list of participates in the automatic exchange of information on bank interest paid to nonresident…
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Court Denies Motion for Preliminary Injunction Prohibiting the IRS from Enforcing the Micro-Captive Disclosure Requirements in Notice 2016-66
On November 1, 2016, the IRS issued Notice 2016-66 imposing new reporting requirements on micro-captives and their material advisors (see prior post describing the Notice). On March 27, 2017,…
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Regulatory Freeze on Tax Guidance Begins to Thaw While Scope of Regulatory Reduction Order Still Unclear
On January 20, 2017, the White House issued a Memorandum freezing all new regulations (former President Obama issued a similar freeze at the start of his administration). In addition, on…
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IRS Provides Sample Letter Informing Taxpayers that Their Account was Referred to a Private Collection Agency
Previously, we discussed Congress’s enactment of the FAST Act requiring the IRS to use private debt collection agencies to recover inactive tax receivables. In September, the IRS announced that it…
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California District Court Finds Failure to File FBARs was Willful Despite Application for Voluntary Disclosure Program
The Bank Secrecy Act requires U.S. taxpayers to file FBARs with the U.S. Treasury disclosing any interest in, or signature authority over, foreign financial accounts with assets in excess of…
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