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The Internal Revenue Service (“IRS”) announced a major expansion of its “Fresh Start” initiative to help struggling taxpayers by taking steps to provide new penalty relief to the unemployed and making Installment Agreements available to more people. The changes include: Certain taxpayers who have been unemployed for 30 days or longer will be able to […]

  The Internal Revenue Service yesterday reopened the offshore voluntary disclosure program to help people hiding offshore accounts get current with their taxes and announced the collection of more than $4.4 billion so far from the two previous international programs. The IRS reopened the Offshore Voluntary Disclosure Program (OVDP) following continued strong interest from taxpayers […]

The Internal Revenue Service today released new proposed guidelines designed to provide relief to more innocent spouses requesting equitable relief from income tax liability. A Notice proposing a new revenue procedure, posted today on IRS.gov, revises the threshold requirements for requesting equitable relief and revises the factors used by the IRS in evaluating these requests. […]

The Internal Revenue Service in coming days will release a new information reporting form that taxpayers will use starting this coming tax filing season to report specified foreign financial assets for tax year 2011. Form 8938 (Statement of Specified Foreign Financial Assets) will be filed by taxpayers with specific types and amounts of foreign financial […]

It is being reported by tax-news.com that the American Embassy in Ottawa has disclosed that the United States Internal Revenue Service (IRS) will shortly announce an easing of its foreign account reporting rules for US citizens living in Canada. Under the IRS’s Foreign Bank Account Report (FBAR) rules, any US person (not necessarily a US […]

In Lampton v. Diaz, 639 F.3d 223 (5th Cir. 2011), the Fifth Circuit held that prosecutorial immunity from suit did not extend to a prosecutor’s post-trial transfer of a defendant’s private federal tax records to a state ethics commission. Between 2003 and 2006, Dunnica Lampton (“Lampton”), the U.S. Attorney for the Southern District of Mississippi, […]

In United States v. Mubayyid, No. 08–1846, 2011 WL 3849749 (1st Cir. Sept. 1, 2011), the First Circuit upheld the defendant’s convictions under 26 U.S.C. §§ 7206(1) and 7212(a), based on his failure to disclose his organization’s non-charitable activities on IRS Form 990. In 1993, Emadeddin Muntasser (“Muntasser”) incorporated Care International, Inc. (“Care”), an organization […]

In United States v. Fumo, 655 F.3d 288 (3d Cir. 2011), the Third Circuit vacated the defendants’ sentence in part because the district court failed to articulate clearly whether its sentencing procedure was a departure or a variance. During his three decades as Pennsylvania state senator, Vincent J. Fumo (“Fumo”) engaged in a wide-ranging scheme […]

In United States v. Renner, 648 F.3d 680 (8th Cir. 2011), the Eighth Circuit upheld the district court’s decision to grant a downward variance in a tax evasion case based on the fact that the defendant had consulted with tax professionals, even though the jury did not believe the defendant met all the requirements for […]

In United States v. Hoskins, 654 F.3d 1086 (10th Cir. 2011), the Tenth Circuit held, inter alia, that a sentencing court was not precluded in appropriate cases from considering unclaimed deductions in determining tax loss under § 2T1.1 of the Sentencing Guidelines. In the present case, however, the lower court had not erred in rejecting […]