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FBAR Penalty Procedures

The IRS announced a rather significant update to FBAR Penalty assessment procedures on May 13, 2015. These procedures are what are to be followed during an FBAR audit whether inside or outside an Opt – out audit. For the most part, this will make the FBAR penalties lower …

What is the FBAR penalty statute of limitations on collections?

For typical IRS tax debts, the statute of limitations on collections is 10 years. In IRS-speak this “statute of limitations” is called the Collection Statute Expiration Date or CSED (pronounced “SEE-said”). And wouldn’t you know it, if you have been assessed an FBAR Penalty (or several) during an FBAR or Opt-Out audit there is an FBAR CSED as well. There is a statute of limitations on collecting FBAR penalties, but …

An OVDP closing agreement that didn’t close?

We have been seeing a relatively new phenomenon lately: The IRS and Department of Justice (DOJ) requesting testimony or documentation from a person going through the OVDP (Offshore Voluntary Disclosure Program ) — or a person who has already completed an Offshore Voluntary Disclosure, signed a Letter 906 and paid all…

IRS Fresh Start Program Tax Lien Removal, Withdrawal, and Thresholds

The improvements to tax liens under the Fresh Start Program are definitely appreciated, and they can do a great job of making some cases move a little quicker and receive a more beneficial outcome. But, seeing as the IRS is never going to make things truly easy, the improvements don’t fix the convoluted mess of tax… 

IRS Fresh Start Program Business and Payroll Taxes

When thinking about the IRS, many people only consider things from an individual standpoint. However, that’s not always the case. Businesses can also fail to pay their taxes and have to sort out their liabilities with the IRS. Whether it’s a C-Corp (Form 1120) having failed to pay their income and payroll taxes or…