The recent Zhang v. United States case, Docket No. 21-17093 (9th Cir. Oct. 18, 2022), serves as a reminder that the Internal Revenue Service (IRS) can force you to disclose and share.
It is crucial to be strategic with information provided to various countries regarding tax issues. Telling one country one story and taking a different position in the United States could lead to some tax adjustments and even a referral to the IRS’s criminal tax division.
On October 11, 2022, the Internal Revenue Service ("IRS") announced significant draft changes to Schedule UTP, "Uncertain Tax Position," and instructions for the 2022 tax year, stating.
A thorough overview of the IRS Criminal Investigation Division’s (“IRS-CI’s”) current voluntary disclosure practice, designed for taxpayers to potentially avoid or mitigate prosecution for violating IRS and information reporting laws.