Contact Paul +

Time limit is exhausted. Please reload CAPTCHA.

FBAR

Tax Court – FBAR civil penalties aren’t taken into account in $2 million whistleblower threshold

Tax Court – FBAR civil penalties aren’t taken into account in $2 million whistleblower threshold

Whistleblower 22716-13W, (2016) 146 TC No. 6 The Tax Court has concluded that penalties for failing to file Form TD F 90-22.1, Report of Foreign Bank and Financial Accounts (Foreign Bank Account Report or FBAR) under 31 U.S.C. sec. 5321(a) are not “additional amounts” for purposes of the $2,000,000 nondiscretionary award threshold under Code Sec. […]

Read the full article →

IRS corrects Notice announcing changes to withholding and FATCA regs

IRS corrects Notice announcing changes to withholding and FATCA regs

Notice 2016 – 08, Timing of Submitting Preexisting Accounts and Periodic Certifications; Reporting of Accounts of Nonparticipating FFIs; Reliance on Electronically Furnished Forms W – 8 and W – 9. To reduce a number of compliance burdens, IRS announced in Notice 2016-8 that it intended to amend several regs with respect to chapters 3 (withholding […]

Read the full article →

Washington Alert – PTIN expiration notices sent; GAO faults IRS phone service; Return preparers and EITC warning; FINCEN and insurance companies

Washington Alert – PTIN expiration notices sent; GAO faults IRS phone service; Return preparers and EITC warning; FINCEN and insurance companies

IRS announced on Jan. 22 that the Return Preparer Office has started mailing Preparer Tax Identification Number (PTIN) expiration notices to tax preparers who have not renewed their PTIN for 2016. (e-News for Tax Professionals 2016-3) According to the agency, some 150,000 such notices will be sent. The notice informs recipients that their PTIN can […]

Read the full article →

Streamlined offshore account compliance guidance for Canadian retirement plan participants

Streamlined offshore account compliance guidance for Canadian retirement plan participants

IRS has added new FAQs to its website on the IRS streamlined offshore account compliance program, that include guidance to participants in Canadian retirement plans.  Click here for the Streamlined Filing Compliance Procedures for U.S. Taxpayers Residing in the United States Frequently Asked Questions and Answers (Updated Jan. 7, 2016) (“Domestic Q&As”).  Click here for […]

Read the full article →

IRS will amend nonresident, etc. withholding and FATCA regs to reduce compliance burdens

IRS will amend nonresident, etc. withholding and FATCA regs to reduce compliance burdens

Notice 2016-8, 2016-6 IRB In a Notice, IRS has announced that it intends to amend several regs with respect to chapters 3 (withholding of tax on nonresident aliens and foreign corporations) and 4 (the Foreign Account Tax Compliance Act; FATCA) of the Code to reduce a number of compliance burdens. Prior to the issuance of […]

Read the full article →

Washington Alert – JCT on List of Expiring Federal Tax Provisions; FATCA ‘Feel Good’ Survey; 2015 Filing Season; CBO on Revenue in 2015 – an infographic

Washington Alert – JCT on List of Expiring Federal Tax Provisions; FATCA ‘Feel Good’ Survey; 2015 Filing Season; CBO on Revenue in 2015 – an infographic

The Joint Committee on Taxation (JCT) on Jan. 8 published a document titled “List of Expiring Federal Tax Provisions 2016-2025.” (JCX-1-16) As described by JCT, the document provides a listing of federal tax provisions (other than those providing time-limited transition relief after the repeal of an underlying rule) that are currently scheduled to expire in […]

Read the full article →

Updated FATCA FAQs Clarify Branch and Disregarded Entity Registration Requirements

Updated FATCA FAQs Clarify Branch and Disregarded Entity Registration Requirements

IRS has recently updated its list of frequently asked questions (FAQs) to clarify branch and disregarded entity (DRE) registration requirements under the Foreign Account Tax Compliance Act (FATCA). In general, unless a specific exception applies, a branch must register as a branch of its owner, rather than as a separate entity. IRS also provides instructions […]

Read the full article →

Washington Alert – GAO report on IRS Collection; Webinar on Independent Contractors; US and Slovak Republic sign IGA; Tax Policy paper on the Cadillac tax

Washington Alert – GAO report on IRS Collection; Webinar on Independent Contractors; US and Slovak Republic sign IGA; Tax Policy paper on the Cadillac tax

A recent report by the Government Accountability Office (GAO) focused on IRS’s collection process and found it heavily relies on the use of automation to categorize and route unpaid tax or unfiled tax return cases for potential selection. (GAO-15-647) The agency’s automated Inventory Delivery System (IDS) is used to categorize and route cases based on […]

Read the full article →

IRS sheds light on when incoming and outgoing FATCA information becomes confidential

IRS sheds light on when incoming and outgoing FATCA information becomes confidential

Legal Advice Issued by Associate Chief Counsel 2015-005 In a redacted Legal Advice Issued by Associate Chief Counsel, IRS has given its opinion on the exact moment when information that it provides to, and information it receives from, foreign tax authorities and other parties pursuant to the Foreign Account Tax Compliance Act (FATCA), becomes protected […]

Read the full article →

Another Circuit says IRS can compel production of foreign bank records

Another Circuit says IRS can compel production of foreign bank records

Chabot, (CA 3 7/17/2015) 116 AFTR 2d ¶ 2015-5060 The Court of Appeals for the Third Circuit, affirming a district court decision, has held that the “required records” exception to the Fifth Amendment privilege against self-incrimination applies to allow IRS to summon foreign bank account records. This is the same conclusion arrived at by the […]

Read the full article →

District Court holds IRS FBAR penalty conduct was capricious, so late payment interest and penalty voided

District Court holds IRS FBAR penalty conduct was capricious, so late payment interest and penalty voided

Moore, (DC VA 7/24/2015) 116 AFTR 2d ¶ 2015-5094 A district court has held that IRS’s conduct in assessing penalties for a taxpayer’s failure to file FBARs (Report of Foreign Bank and Financial Account) with respect to his foreign account was arbitrary and capricious, in violation of the Administrative Procedures Act (APA). As a result, […]

Read the full article →

Washington Alert – APTC face spotlight; TIGTA on IRS Automated Underreporter Program; 3 More Banks enter Swiss Bank Program

Washington Alert – APTC face spotlight; TIGTA on IRS Automated Underreporter Program; 3 More Banks enter Swiss Bank Program

The use of the advance premium tax credit (APTC) provided for by the Affordable Care Act and the administration of the tax credit are now in the spotlight of Sen. Orrin Hatch (R-UT), chairman of the Senate Finance Committee. During July 16 testimony before Hatch’s panel, the Government Accountability Office (GAO) revealed it had conducted […]

Read the full article →

Reminder: Report Foreign Bank and Financial Accounts by June 30

Reminder: Report Foreign Bank and Financial Accounts by June 30

IR 2015-92 IRS has issued a reminder that the due date for filing 2014 Form 114, Report of Foreign Bank and Financial Accounts (FBAR), is Tuesday, June 30. Background. U.S. citizens and resident aliens are legally required to report any worldwide income, including income from foreign trusts and foreign bank and securities accounts. In most cases, […]

Read the full article →

New guidance explains how certain taxpayers can file delinquent FBARs without penalty

New guidance explains how certain taxpayers can file delinquent FBARs without penalty

IRS has provided procedures for filing a delinquent Report of Foreign Bank and Financial Accounts (FBAR) (FinCEN Form 114, previously Form TD F 90.22.1), without penalty, by taxpayers that use neither the Offshore Voluntary Disclosure Program (OVDP) nor the Streamlined Filing Compliance Procedures. Background. The Bank Secrecy Act (BSA) gave the Treasury Department authority to […]

Read the full article →

District Court Explores Proper Review of FBAR Penalty Issues & Largely Rules Against Taxpayer

District Court Explores Proper Review of FBAR Penalty Issues & Largely Rules Against Taxpayer

Moore v. U.S., (DC WA 04/01/2015) 115 AFTR 2d ¶2015-591   A district court has largely dismissed a taxpayer’s challenges to his penalty for failing to file FBARs (Report of Foreign Bank and Financial Account) with respect to his foreign account, finding that he failed to make the required filings, he had no reasonable cause […]

Read the full article →

Recent FATCA guidance clarifies Form 8966 filing requirements

Recent FATCA guidance clarifies Form 8966 filing requirements

IRS has added new frequently asked questions (FAQs) concerning Foreign Account Tax Compliance Act (FATCA) reporting to its website. Specifically, the new FAQs clarify certain aspects of the requirement and deadline for filing Form 8966 (FATCA Report) for certain filers.  Click here to view the new FATCA FAQs concerning Form 8966 (FATCA Report). Background on FATCA. The Hiring […]

Read the full article →

IRS reminds persons with foreign connections of pending deadlines & other filing requirements

IRS reminds persons with foreign connections of pending deadlines & other filing requirements

IR 2015-70 In a news release, IRS has provided filing advice for persons who had 2014 connections to foreign countries. For example, it reminded U.S. citizens and resident aliens, including those with dual citizenship who have lived or worked abroad during all or part of 2014, that they may have a U.S. tax liability and […]

Read the full article →

IRS Reminds Those with Foreign Assets of U.S. Tax Obligations

IRS Reminds Those with Foreign Assets of U.S. Tax Obligations

WASHINGTON — The Internal Revenue Service  today reminded U.S. citizens and resident aliens, including those with dual citizenship who have lived or worked abroad during all or part of 2014, that they may have a U.S. tax liability and a filing requirement in 2015. Most People Abroad Need to File A filing requirement generally applies […]

Read the full article →

Final Regs Issued On Specified Foreign Financial Asset Reporting

Final Regs Issued On Specified Foreign Financial Asset Reporting

T.D. 9706, 12/11/2014; Reg. § 1.6038D-1, Reg. § 1.6038D-2, Reg. § 1.6038D-3, Reg. § 1.6038D-4, Reg. § 1.6038D-5 , Reg. § 1.6038D-7, Reg. § 1.6038D-8   IRS has issued final regs that provide guidance on the requirement under Code Sec. 6038D that individuals attach a statement to their income tax return that provides information on […]

Read the full article →

Santa Rosa Tax Return Preparer Pleads Guilty to Tax Fraud and Failing to Report Foreign Bank Accounts

Santa Rosa Tax Return Preparer Pleads Guilty to Tax Fraud and Failing to Report Foreign Bank Accounts

Santa Rosa Tax Return Preparer Pleads Guilty to Tax Fraud and Failing to Report Foreign Bank Accounts, as reported by the DOJ. SAN FRANCISCO – Efrain Arturo Jovel pleaded guilty today to filing two false tax returns and failing to report his financial interest in foreign bank accounts, U.S. Attorney Melinda Haag and Internal Revenue […]

Read the full article →
Page 1 of 3123
Meet Paul Raymond

Meet Paul Raymond

Mr. Raymond is a sought after speaker in tax controversy law by many attorney, accountant, and business groups and at the request of the Internal Revenue Service, has presented programs at the IRS Nationwide Tax Forum, attended by tax professionals throughout the United States.

Additionally, he continues to be an active member in the Section of Taxation, American Bar Association, where he was the Past Chair of the Employment Taxes Committee.

Read More

Connect With Paul on Social Media

Practice Areas & Information

Certifications &
Associations
Member CA Bar Member Orange County Bar US Tax Court Attorney