New York Utilizing Electronic Data Records for Tax Audits
Taxpayers claiming residency outside of New York while maintaining ties to New York, such as an apartment, room, or other ties in New York, may be exposing themselves to a…
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Forms and Filings Internal Revenue Code Internal Revenue Service International Taxation Tax Compliance
Forms 5471 and 5472 – Meaning of Substantially Complete
The IRS recently released a new International Practice Unit (“IPU”) on failures to file form 5471. IPUs are meant to act as a guide for IRS examiners and give insight…
Compliance Issues France Germany International Taxation International Treaty Switzerland Tax Compliance
UBS to Share Client Information with France
In recent years, Switzerland’s strict bank secrecy laws have made assets in the country a target of investigation for tax authorities around the world. This week, the Swiss Federal Tax…
Compliance Issues FATCA Internal Revenue Code Internal Revenue Service OVDI Streamlined Streamlined Procedure Tax Amnesty Tax Compliance
Whistleblowers and § 6103(n)
On December 20, 2006, the Tax Relief and Health Care Act (the “Act”) was enacted. The Act amended Internal Revenue Code § 7632 and established a Whistleblower Office in the…
Foreign Tax Preparation Forms and Filings International Taxation International Treaty Tax Compliance
Taxation of Consulate Workers in the United States
Resident aliens working for foreign consulates located within the United States may wonder how much, if any, of their income is subject to U.S. taxation. The first place to look…
Compliance Issues Foreign Tax Preparation Forms and Filings Internal Revenue Code Internal Revenue Service Tax Compliance
3520 Filing Deadline without a Return
Form 3520 Annual Return to Report Transactions with Foreign Trusts and Receipt of Certain Foreign Gifts and Form 3520-A Annual Information Return of Foreign Trust with a U.S. Owner are…