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Showing posts from July, 2019

Will America go from hunter to hunted in cross-border tax evasion?

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On 1 May 2019, the US Department of Justice (DOJ) announced that the IRS had obtained a court order authorizing the service of “John Doe” summonses on three US banks in connection with Finnish residents who were regularly and frequently using US bank payment cards in Finland. The court order was issued by the US District Court for the Western District of North Carolina, following an ex parte petition submitted on 23 April 2019. DOJ petitioned the court after the IRS received an “Exchange of Information” request from the Finnish tax authorities. The Finnish tax authorities’ request was made following a compliance initiative targeting the use of non-Finnish bank cards in Finland. Investigation into users of such bank cards showed a high rate of noncompliance with Finnish tax reporting and payment obligations. In this particular case, the Finnish tax authorities identified three US bank-issued payment cards repeatedly used in Finland, indicating to the Finnish tax authorities that there w…

The IRS Large Business and International Division (LB&I) Announces the Approval of Six Additional Compliance Campaigns

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The IRS Large Business and International division (LB&I) announces the approval of six additional compliance campaigns.
To date, LB&I has announced a total of 59 campaigns.

The campaigns described below were identified through LB&I data analysis and suggestions from IRS employees. LB&I's goal is to improve return selection, identify issues representing a risk of non-compliance, and make the greatest use of limited resources.

The new campaigns are: S Corporations Built in Gains TaxPractice Area: Pass Through Entities

Lead Executive: Holly Paz, director of Pass Through Entities

C corporations that convert to S corporations are subjected to the Built-in Gains tax (BIG) if they have a net unrealized built-in gain and sell assets within 5 years after the conversion. This tax is assessed to the S corporation. LB&I has found that S corporations are not always paying this tax when they sell the C corporation assets after the conversion. LB&I has developed comprehensive …