IRS Offers Settlements to Some Micro-Captive Insurance Taxpayers

By Barbara T. Kaplan & Josh Prywes on September 20, 2019

On Sept. 16, 2019, the IRS announced it is offering settlements to certain taxpayers with open audits of micro-captive insurance transactions. The IRS has targeted these micro-captive insurance transactions since 2014, and they were designated as transactions of interest in 2016.1 Although micro-captive insurance transactions have gained popularity among closely held entities, the IRS has challenged such transactions as abusive, stating that they “are inconsistent with arm’s length transactions and sound business practices.”…

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 on 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 on 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,…

E2 Law Blog

Investors in Many Syndicated Conservation Easement Deals Must Notify the IRS

By Barbara T. Kaplan & Marvin A. Kirsner on December 30, 2016

The IRS has designated certain syndicated conservation easement transactions as “listed transactions.” This will require taxpayers who have invested in such transactions to file a notice with the IRS. It will also result in reporting and list maintenance obligations for professionals (law firms, accountants, appraisers, etc.) who provided material advice on such transactions. If the required notice is not provided, severe penalties will be imposed. Conservation easements, a tax planning technique that has gained popularity with…

GT Israel Law Blog

Just Before the New Jewish Year: U.S. FATCA Information Exchange Goes into Effect in Israel at the End of September

By Barbara T. Kaplan & Pallav Raghuvanshi on September 26, 2016

Come the end of September 2016, the Israeli Tax Authority will start forwarding data collected on U.S. citizens and green card holders with financial accounts in Israel to the U.S. Internal Revenue Service (IRS). This transferring of information is part of FATCA (the U.S. Foreign Account Tax Compliance Act of 2010), based on an agreement between Israel and the United States. While FATCA applies on a worldwide basis, the U.S. has entered into intergovernmental agreements (IGAs)…

Barbara T. Kaplan

IRS Offers Settlements to Some Micro-Captive Insurance Taxpayers

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

Investors in Many Syndicated Conservation Easement Deals Must Notify the IRS

Just Before the New Jewish Year: U.S. FATCA Information Exchange Goes into Effect in Israel at the End of September

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