The Internal Revenue Service has announced that they plan on assign tax compliance cases to Revenue Officers for those individuals that are high income earners and have failed to file income tax returns.
Nina Olson of the Taxpayer Advocate Service has released an map depicting the tax process and how it mimics a subway map.
Court of Federal Claims Rejects the Holding in Colliot and holds that the FBAR Penalties are not limited to $100,000
The United States Court of Federal Claims recently rendered an opinion, see link below, holding that the FBAR Penalties are not limited to $100,000 for wilful failure to file FBAR reports.
In United States v. Colliot (W.D. Texas No. AU-16-CA-01281-SS), a case which was brought by the United States to obtain a judgment for FBAR penalties, the court granted Colliot's motion for summary judgment, holding that penalties in excess of $100,000 is unlawful.
The IRS has announced that it is planning on ending the Offshore Voluntary Disclosure Program. The program was designed for taxpayers that may be subjected to criminal liability and or substantial civil penalties for failing to report foreign assets to the federal government.
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