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Tax Compliance Blog

Holland & Knight's Tax Compliance Blog provides insights and analysis on relevant tax issues. It focuses primarily on tax cases, IRS releases and announcements, as well as news from Treasury pertaining to tax. Foreign issues, such as compliance associated with ownership of foreign investments; participation in the IRS voluntary disclosure programs; compliance associated with the Foreign Account Tax Compliance Act (FATCA) and Foreign Bank Account Reporting (FBAR) filing requirements are also discussed.

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There is a great deal of excitement about the new tax incentive for investments in low-income communities designated as "Opportunity Zones." This enthusiasm is being expressed by investors, those who want to attract investment, and the state, local and tribal governments that have high hopes for the economic development it can spur in the low-income communities they serve.
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As a result of the complexity of the Internal Revenue Code and introduction of new provisions courtesy of Congress, taxpayers are challenged with filing correct and accurate tax returns. Taxpayers can make mistakes, which can be resolved proactively through an amended return, or defensively through an examination.  This article will review the process by which the taxpayer is entitled to a refund, and discuss the applicable statutes of limitation for seeking a refund in examination, administrative appeals, and in the United States Tax Court (USTC).
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The Tax Cuts and Jobs Act (the Act) makes important changes to sales and other dispositions of partnership interests, which require immediate changes to purchase agreements.
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February 20, 2018
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The U.S. Department of the Treasury's Financial Crimes Enforcement Network (FinCEN) on Aug. 22, 2017, continued expanding its Geographic Targeting Orders (the GTOs) with respect to beneficial ownership transparency in real estate transactions. The revised GTOs issued on Aug. 22 expanded the prior GTOs by, among other changes, adding additional jurisdictions to the previous GTOs and closing a loophole in the prior GTOs by including wire transfers as part of the triggering transactions.
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August 24, 2017
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The U.S. Department of the Treasury announced on July 7, 2017, in Notice 2017-38 (the Notice) that it has identified as "significant tax regulations" eight sets of U.S. federal tax regulations that were issued between Jan. 1, 2016, and April 21, 2017.
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July 11, 2017
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With the upcoming Republican control of the executive and legislative branches, tax changes are certain to occur. As articulated thus far, President-Elect Donald Trump has proposed the elimination of the federal estate tax in favor of a deferred capital gains tax on appreciated assets in excess of $10 million, excluding small businesses and family farms.
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December 12, 2016
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The IRS currently offers the following five programs for noncompliant taxpayers: (i) the Offshore Voluntary Disclosure Program (OVDP), (ii) Streamlined Domestic Offshore Procedures, (iii) Streamlined Foreign Offshore Procedures, (iv) Delinquent FBAR Submission Procedures and (v) Delinquent International Information Return Submission Procedures. 
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December 7, 2016
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With Republicans in control of the U.S. Senate, the U.S. House of Representatives and the White House starting in 2017, the federal government is now better positioned to move forward on comprehensive tax reform. It is expected that upcoming tax reform efforts will build on the principles set forth in the House Republicans' "A Better Way" proposal, as well as the tax proposals advanced by President-Elect Donald Trump during the course of his campaign.
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The U.S. Treasury and the IRS issued the 2016-2017 Priority Guidance Plan this week. This year’s plan includes 281 projects that the Treasury and the IRS have identified as priorities.
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The IRS recently issued Notice 2016-46, requiring that individuals with inactive or old individual taxpayer identification numbers (ITINs) renew their ITINs. These renewals impact individuals who have not used their ITINs for three consecutive years or had received ITINs prior to 2013.
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August 9, 2016
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Offshore Tax Compliance Attorney Kevin Packman discuses why gifts and inheritances from abroad, as well as foreign lottery winnings, raise a variety of lesser-known tax return filing rules.
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There are options taxpayers may consider when faced with filing an international information return after the Internal Revenue Service's due date.
March 23, 2016
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This article discusses the rules for determining which taxes levied by foreign governments are creditable for U.S. income tax purposes.
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February 8, 2016
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The Internal Revenue Service issued proposed regulations that would eliminate the requirement that taxpayers include a copy of an Internal Revenue Code Section 83(b) election with their returns.
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January 28, 2016
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Attorney Kevin Packman will serve as technical editor and frequent contributor for Steve Leimberg's International Tax Planning Newsletter.
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January 19, 2016
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The Treasury Inspector General for Tax Administration (TIGTA) issued a report reviewing the long-term travel of certain IRS executives and found that nine of the thirty one executives whose records they studied made mistakes on their taxes. The mistakes pertained to the taxability of travel reimbursements they received.
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January 18, 2016
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Shortly before December 30, 2015, the media reported that Julius Baer Group AG expected to pay about $547 million to settle the U.S. investigation into how the bank (and its bankers) assisted U.S. taxpayers in evading tax. This investigation began more than 4 years ago, and followed similar investigations into UBS Group AG and Credit Suisse Group AG.
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January 4, 2016
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Tax compliance remains important for international travel purposes, as a new bill may give the State Department authority to revoke or deny passports to people who owe the U.S. government more than $50,000 in back taxes. Attorney Kevin Packman comments on the proposal and its constitutionality.
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December 14, 2015
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A recent IRS Chief Counsel Advice (CCA) clarifies who may sign a limited liability company's (LLC's) tax return when the LLC has a corporate managing member. CCA 201536025 addresses a situation in which a LLC (LLC-1) taxed as a corporation is managed by another LLC (LLC-2). LLC-2 is a single-member LLC, which is solely owned by a corporation. The CCA concludes that the officer of the corporation that owns LLC-2 has authority to sign LLC-1's return and the IRS can rely on the signature absent proof to the contrary indicating that the officer does not have such authority.
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September 22, 2015
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The Internal Revenue Service has proposed regulations providing guidance to U.S. taxpayers who receive gifts or inheritances from individuals who have expatriated. Attorney Kevin Packman said the bottom line on these new rules is that there will be “more taxes, taxes, taxes” facing expatriates and their families.
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September 14, 2015
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