LEGAL COUNSEL IN DOMESTIC AND INTERNATIONAL TAX CONTROVERSY AND COMPLIANCE MATTERS

Commentary

May 10, 2013

Tax administrations of the U.S., Australia, and the U.K. have announced a plan to share tax information regarding trusts and entities with assets of residents of jurisdictions worldwide.  They have developed a plan to share data and preliminary analysis to other tax administrations where requested.

IR-2013-48


April 17, 2012

Chief Counsel Advice 201214023 describes the conditions under which a U.S. person working overseas is subject to the detached worker rule, noting that that the detached worker rule applies if the employee is transferred to work in a foreign location for a period of five years or less.  CCA 201214023 provides that a U.S. person transferred permanently by his employer to work in a foreign country would be subject to foreign social security taxes and not U.S. social security taxes.

April 10, 2012

The IRS Taxpayer Advocate Service has launched a pilot program in certain offices to test virtual audits, based upon their meeting with Swedish Tax Authorities.  Under this program, a taxpayer would go to an office with the program, sit down in front of a computer, and have a virtual face-to-face meeting with a case advocate.  You can read more about the program here.

http://www.taxpayeradvocate.irs.gov/Blog/virtual-face-to-face-audits

April 9, 2012

IRS Chief Counsel Notice CC-2012-008 provides coordination procedures for the economic substance doctrine and related penalties.


February 8, 2012

The IRS and Treasury have issued proposed regulations under FATCA.  Further, the United States has issued a joint statement with the governments of France, Germany, Italy, Spain and the United Kingdom regarding an intergovernmental approach to implementing FATCA and increasing international tax compliance.  More infomation here.