irstaxlitigation Blog

Audit of the Offshore Voluntary Disclosure Program

The Treasury Inspector General for Tax Administration (“TIGTA”) completed an audit of the Offshore Voluntary Disclosure Program (“OVDP”). US citizens are taxed on their worldwide income and must report bank accounts when their aggregate balance exceeds $10,000. The OVDP and other similar programs allow taxpayers a mechanism to come forward and get into compliance with […]

U.S. Department of Justice Launches Investigation into Panama Papers

A few weeks ago the world was introduced to one of the largest information leaks ever seen: over 11.5 million documents and 2.6 terabytes of information from the Panamanian law firm Mossack Fonseca went public.  While the leak does not necessarily stamp all those involved with guilty convictions for tax evasion, money laundering, or any […]

Understanding the Panama Papers

Over the past few years, the IRS has increased its attention on offshore bank accounts, earmarking much of its limited budget, staff, and resources towards initiatives such as the Offshore Voluntary Disclosure Program (OVDP) and Swiss Bank Program, and pushing strict compliance of foreign bank and financial account reporting through enforcement measures such as the […]

What’s in a Name: Defining Employees and Independent Contractors

In the classic story of “Romeo and Juliet” there is a well-known and often repeated line, “What’s in a name?” In the tax world, a name can mean the difference of thousands of dollars. It is important for business owners, employers, employees and independent contractors to understand the distinction between titles and to plan for […]

Less Audits? Not Necessarily A Good Thing

IRS budget cuts may not appear entirely bad. With a reduced budget comes a reduction in the manpower and resources necessary for the IRS to conduct audits. Less audits means less need for taxpayers to concern themselves with the possibility of retaining records for years or, to some, the need to be entirely truthful on […]