The IRS published extensive 544-page final regulations on Foreign Account Tax Compliance Act (FATCA), finalizing the 2012 proposed regulations. The final regulations address detailed taxpayer comments on the need to reduce FATCA administrative burdens and address technical implementation. The regulations are effective January 28, 2013. For an overview of the final regulations see the IRS… Continue Reading
Category Archives: Compliance
Subscribe to Compliance RSS FeedIRS Explains Requirements for Adequate Disclosure to Avoid Penalties
Posted in Compliance, ProcedureIn Rev. Proc. 2012-51, the IRS issued its annual update to its prior guidance on what constitutes adequate disclosure on a tax return to avoid certain accuracy and tax-preparer penalties. According to the IRS, the changes from the prior year are editorial only and not substantive. The guidance provides detailed rules as to when disclosure… Continue Reading
Final Repair Regs Expected in 2013 with 2014 Effective Date
Posted in Compliance, Deductions, GeneralThe IRS has announced a 2013 publication date and January 1, 2014 effective date for the final regulations relating to when to capitalize or expense payments relating to tangible property (the so-called “Repair Regs”). The IRS Notice contains details as to when taxpayers will be permitted to apply either the final regulations or the temporary regulations… Continue Reading
IRS Issues New FBAR Guidance – Updated FAQs and New Streamlined Procedures for Low-Risk Cases
Posted in Compliance, General, InternationalThe IRS published the anticipated update to the Frequently Asked Questions relating to the Offshore Voluntary Compliance Initiative (OVDI) relating to reporting of foreign financial accounts (commonly referred to as the “FBAR” reporting). The guidance also includes favorable rules for (1) U.S. citizens living abroad and dual citizens with low compliance risks (generally less than… Continue Reading
IRS Issues Guidance on Capitalization vs. Repair Expense Including Automatic Accounting Method Changes
Posted in Compliance, DeductionsThe IRS released two revenue procedures that describe how taxpayers can obtain automatic consent to change their accounting methods to comply with the recent temporary tangible property capitalization vs. repair regulations. Revenue Procedure 2012-19 details repair and maintenance, materials and supplies, and related method changes resulting from the temporary regulations. Revenue Procedure 2012-20 addresses depreciation,… Continue Reading
Final Regulations On The Redesigned Form 990 For Exempt Organizations
Posted in Compliance, Tax ExemptThe IRS finalized regulations (T.D. 9549) implementing the redesigned Form 990, Return of Organization Exempt from Income Tax. The final regulations largely adopt the temporary and proposed regulations with some modifications. The final regulations make permanent new threshold amounts for reporting compensation, require that compensation be reported on a calendar-year basis and change rules requiring information reporting… Continue Reading
FBAR Voluntary Disclosure – IRS Provides Short-term Extension to September 9
Posted in Compliance, General, International, Litigation/ControversyNOTE (Aug. 29, 2011): The IRS clarified that the Sept. 9, 2011, extension also applies to taxpayers filing delinquent FBARs pursuant to IRS Q&A 17 and 18 for the simplified program applicable to taxpayers who did not owe tax but failed to file the appropriate tax forms. _________________________________________________________ Due to Hurricane Irene, the IRS extended… Continue Reading
IRS Reminds Taxpayers of Aug. 31 Deadline for FBAR Voluntary Disclosure
Posted in Compliance, General, International, Litigation/ControversyThe IRS issued a press release reminding taxpayers that they have until August 31 to join the 2011 Offshore Voluntary Disclosure Initiative. According to the press release, the 2011 initiative offers benefits to encourage taxpayers to come forward rather than risk detection by the IRS, observing that taxpayers hiding assets offshore who do not come… Continue Reading
IRS Guidance on Carryover Basis Election for 2010 Decedent Estates
Posted in Compliance, Estate and GiftThe IRS issued important procedural guidance on how estates for decedents dying in 2010 may elect out of the estate tax, thereby giving up the favorable income tax basis step up at death. Form 8939, the basis allocation form required to be filed by executors opting out of the estate tax, is due Nov. 15,… Continue Reading
IRS Revises FAQs on Schedule UTP – Reporting Uncertain Tax Positions
Posted in ComplianceThe IRS updated their Schedule UTP Frequently Asked Questions, answering many common questions corporate taxpayers had in preparing their returns. The FAQs address questions such as (1) when interest and penalties must be included in a ranking of the tax position; (2) the definition of a reserve; (4) whether to file Schedule UTP if the… Continue Reading
New Phased Implementation of Certain FATCA Requirements
Posted in Compliance, InternationalThe looming 2013 effective date of new Foreign Account Tax Compliance Act (FATCA) reporting for Foreign Financial Institutions (FFIs) has some new relief. In Notice 2011-53, the Treasury announced new phased-in implementation because “Chapter 4” of FATCA creates the need for significant modifications to the information management systems of FFIs, withholding agents, and the IRS. … Continue Reading
Subscribe to this blog via RSS
Retail Law Advisor
Goulston & Storrs
Follow us on Twitter
Subscribe to this blog by email
Follow Us on LinkedIn