The Foreign Bank and Financial Accounts Report (FBAR) is a mandatory filing requirement for U.S. citizens, residents, and entities, including corporations, partnerships, and trusts, that have financial interests in or signature authority over foreign financial accounts exceeding $10,000 at any time during the calendar year. Administered by the Financial Crimes Enforcement Network (FinCEN), the FBAR […]
An Overview of the Bipartisan Budget Act of 2015 Centralized Partnership Audit Regime
The Bipartisan Budget Act of 2015, also known as the BBA, is the centralized partnership audit regime that is intended to apply to partnership entities unless the partnership elects out of the regime. This was found necessary in dealing with the unique nature of partnerships, where the partners file returns individually, and yet the partnership […]
Procedures Involved in Jeopardy and Termination Assessments
While it is true that jeopardy and termination assessments dispense with certain requirements that are usually followed in regular deficiency assessment procedures (for instance, the issuance of a notice of statutory deficiency), it does not mean that no protocols are in place. Should the IRS opt to exercise its authority in initiating jeopardy and termination […]
Abatement of IRS Tax Assessments
The word “abate” means to lessen, reduce, or remove. Abatement of an assessment also carries the same meaning. That is, an IRS assessment may be lessened, reduced, or removed under certain circumstances, including a showing that the assessment is: Excessive; Assessed after the expiration of the statute of limitations; Erroneous or illegal It is important […]
The Potential Outcomes of a Notice of Assessment? (Besides Paying The IRS)
It seems easy to surmise that a notice of assessment of a taxpayer’s liability is intended to inform the taxpayer that he is required to pay his tax liability. The end game for any assessment is, of course, the collection of taxes. Sometimes, however, the notice of assessment may not actually end in the taxpayer […]
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