Syndicated Conservation Easements: Under New Fire as IRS Enforcement Action Increases

By Michelle Ferreira, Barbara T. Kaplan & Jennifer A. Vincent

November 14, 2019

While the IRS has been cracking down on syndicated conservation easements for over ten years, earlier this year Chuck Rettig, the Commissioner of the IRS, announced several campaign areas upon which the IRS would heighten focus in the coming year. Following through on this promise, on Nov. 12, 2019, the IRS announced a significant increase in enforcement actions for syndicated conservation easements in Issue Number IR-2019-182. This GT Alert explains what a syndicated conservation…

Legacy Advisors

Now Is the Time to Consider Voluntary Disclosure: Advancement of the IRS Campaign on Withholding Tax Noncompliance for Forms 1042, 1042-S

By Michelle Ferreira & Jennifer A. Vincent

June 19, 2019

Campaign for Compliance Last year the IRS announced a new campaign to target “Withholding and International Individual Compliance” regarding Forms 1042 and 1042-S. Those who make payments of certain U.S.-source income to foreign persons must comply with withholding, deposit, and reporting requirements. The IRS campaign promised to address “withholding agents who make such payments but do not meet all their compliance duties.” In accordance with this promise, the IRS initiated the campaign, uncovering several thousand…

Legacy Advisors

IRS Releases New Voluntary Disclosure Procedures for Post 9-28-2018 Offshore and Domestic Disclosures

By Barbara T. Kaplan, Michelle Ferreira, Scott E. Fink, Courtney A. Hopley & Shira Peleg

December 3, 2018

On Nov. 29, 2018, the IRS released a memorandum with new procedures for all voluntary disclosures following the end of the Offshore Voluntary Disclosure Program (OVDP) on Sept. 28, 2018. The new voluntary disclosure procedures apply to both domestic and offshore voluntary disclosures. What’s Changed? Background OVDP was initiated in 2009 and designed to bring taxpayers with undisclosed foreign income, accounts, and assets into compliance for U.S. income tax purposes. Taxpayers who were eligible to…

Legacy Advisors

IRS Announces it Will End the Offshore Voluntary Disclosure Program Effective September 28, 2018

By Michelle Ferreira, Barbara T. Kaplan, Scott E. Fink & Courtney A. Hopley

March 16, 2018

The IRS announced that it will end the Offshore Voluntary Disclosure Program (OVDP), effective September 28, 2018. The IRS is pressing taxpayers with undisclosed foreign accounts, entities and income to come forward before the September 28, 2018 deadline and become compliant. Therefore, US taxpayers who have unreported foreign assets and income have a limited amount of time to participate in the OVDP before the program ends. If they do not, they may face dire penalties,…

Michelle Ferreira

Syndicated Conservation Easements: Under New Fire as IRS Enforcement Action Increases

Now Is the Time to Consider Voluntary Disclosure: Advancement of the IRS Campaign on Withholding Tax Noncompliance for Forms 1042, 1042-S

IRS Releases New Voluntary Disclosure Procedures for Post 9-28-2018 Offshore and Domestic Disclosures

IRS Announces it Will End the Offshore Voluntary Disclosure Program Effective September 28, 2018

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