<p>Have you been contacted by a foreign bank and asked to provide documentation to confirm your status as a U.S. person or foreign person pursuant to the Foreign Account Tax Compliance Act (FATCA). Are you being asked to provide a (1) Form W-9 (Request for Taxpayer Identification Number and Certification), or (2) Form W-8BEN (Certificate&#8230; </p> <div class="clear"></div> <p><a href="https://walk-law.com/foreign-account-tax-compliance-act-fatca-form-w-9/" class="excerpt-re

<p>Have you received a letter from the Internal Revenue Service (IRS) asking you to come in for an interview? Are you the subject of an IRS examination or target of an IRS criminal case? We are likely to see more activity in the international enforcement area. Internal tax enforcement is a top priority for the&#8230; </p> <div class="clear"></div> <p><a href="https://walk-law.com/the-panama-papers/" class="excerpt-read-more">Read More</a></p>

<p>Mr. Walker was invited to Washington D.C. by the Taxation Section, State Bar of California, to present a position paper regarding how to classify a dual resident taxpayer (file a Form W-9 or a Form W8-BEN).  The paper was presented to the Internal Revenue Service, United States Treasury Department, U.S. Tax Court, and Congressional personnel&#8230;. </p> <div class="clear"></div> <p><a href="https://walk-law.com/dual-residents-treasury-regulations-section-301-7701b-7-treat

<p>The Department of Justice has stepped up is prosecutions on the criminal and civil enforcement side against employers who pyramid (business withholds taxes from employees but intentionally fails to remit them to the IRS over several quarters), pay employees in cash, and file false payroll tax returns or simply fail to file. Employers have a&#8230; </p> <div class="clear"></div> <p><a href="https://walk-law.com/employment-tax-enforcement/" class="excerpt-read-more">Read Mor

<p>This article examines the concept of willfulness in the context of international tax enforcement, focusing on the factors that can transform a civil tax case into a criminal tax matter. &nbsp;</p>

<p>Tax professionals who advise clients on issues with FinCEN Form 114, Report of Foreign Bank and Financial Accounts (FBAR), should become familiar with IRS Memorandum SBSE-04-0515-0025, “Interim Guidance for Report of Foreign Bank and Financial Accounts (FBAR) Penalties” (5/13/15). The guidance is significant because it provides procedures to ensure consistency and efficiency in the IRS’s&#8230; </p> <div class="clear"></div> <p><a href="https://walk-law.com/irs-provides-gu

<p>On June 18, the IRS announced major changes to its offshore voluntary compliance programs, providing new options to help taxpayers residing both overseas and in the United States. The changes are intended to give thousands of people a new avenue to comply with their U.S. tax obligations (IR-2014-73). Modifications were made in response to public&#8230; </p> <div class="clear"></div> <p><a href="https://walk-law.com/guide-irs-new-streamlined-offshore-compliance-program/" cl

<p>In the government’s criminal investigation and charging of Credit Suisse AG with helping U.S. taxpayers evade taxes, the IRS used a new and little-known provision of the code, section 6201(a)(4), to ensure that the Swiss bank paid $666.5 million in restitution to the Service. This article examines the effect of the IRS’s restitution-based assessment on&#8230; </p> <div class="clear"></div> <p><a href="https://walk-law.com/swiss-bank-credit-suisse-impact-u-s-clients/" class