New User Fees for Processing Installment Agreements and Offers in Compromise

Effective Jan. 1, 2014, processing fees for standard installment agreements and doubt as to collectability offers will increase. Fees for direct debit installment agreements are unchanged. Low income fees and fee waivers are also unchanged. 


The notice of proposed rule making proposed to increase the fee under § 300.1 for entering into an installment agreement from $105 to $120 and to increase the fee under § 300.2 for restructuring or reinstating an installment agreement from $45 to $50.

Under the notice of proposed rule making, the fee for a direct debit installment agreement remained $52, and low-income taxpayers, as defined in § 300.1(b)(2), would continue to pay $43 for any new installment agreement, including a direct debit installment agreement. The notice of proposed
rule making also proposed to increase the fee under § 300.3 for processing an offer in compromise from $150 to $186.

Offers based on doubt as to liability and offers from low-income taxpayers continue to be excepted from a user fee.

The new fee rates for both installment agreements and offers in compromise will be effective January 1, 2014.

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U.S. Signs 6 More FATCA Agreements!

The US Treasury Department's web site indicates that the U.S. has signed FATCA agreements with:

1. Bermuda
2. Guernsey
3. the Isle of Man, 
4. Jersey
5. Malta and 
6. the Netherlands.

The US Treasury Department's web site also reflects that with the six new agreements are total of 18 of such signed intergovernmental agreements (IGAs). 

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FATCA FFI List Resources and FFI List FAQs are Now Available

• The FATCA FFI List Resources and Support Information Webpage has been posted to the FATCA Website. 
• In addition, the FATCA FFI List Frequently Asked Questions (FAQs) have been posted to the FATCA Website.

What taxpayers representatives should be paying attention to in these FATCA discussions, among other things, is that the form of the FATCA submissions entitled "Schema" is a uniform computer readable report. This is the same language/requirement which is being utilized in discussions regarding intergovernmental agreements.

So effectively, in the not-too-distant future, we may be seeing foreign banks submitting their "Schema" to their government to be shared with the US and other foreign governments; which can then be used by the IRS or the other home country to match up the information in the "Schema" against that depositors local tax report!

Some of the requirement currently being discussed include that these "Schema" contain the taxpayers  home country identification number. So for a US taxpayer it would contain their Social Security number.

Where that happens, tax advisers need to advise their clients that it's no longer a question of if; rather it's a question of when, the US and other governments are able to match the information from these intergovernmental agreements to an individual US taxpayers transcript information or other country's tax information.

No one can tell exactly when this ability to cross match foreign information with US  taxpayers transcripts will occur; however a good guess would be as soon as 3 to 5 years in the future; given all the logistics associated with such a program.

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Marini & Associates, P.A. Wishes You Happy Hollidays!

View this email in your browser Marini & Associates, P.A. wishes you a  Merry Christmas, Happy Hanukkah and a Happy and Prosperous  New Year!   Tax Litigation, Tax Audits,   Tax Appeals & Tax Collections ¡Feliz Navidad y Prospero Año Nuevo!     WWW.TAXLAW.MS Copyright © 2013 Marini & Associates PA, All rights reserved. We are your partners... Our mailing address is: Marini & Associates PA 8950 SW 74th Court Suite 1811 Miami, FL 33156-3177 Add us to your address book unsubscribe from this list    update subscription preferences

Walliser Kantonalbank Becomes the Latest Swiss Bank to Accept US Deal.

Yesterday we posted "Today is the Swiss Bank's Deadline to Reveal Hidden US Accounts to the IRS!" which discussed that approximately 300 Swiss Banks have until the end of today, Monday December 16, 2013, to decide whether to turnover their records to the IRS.

Today Walliser Kantonalbank became the latest Swiss bank to Accept US Deal.to avoid prosecution.

Walliser Kantonalbank said in a statement that it had never focused on acquiring American clients but that it was unable to guarantee that all U.S. customers had fully complied with their U.S. tax obligations.


About 100 banks are expected to take part in the scheme by the end of the year.

The U.S. Department of Justice (DOJ) warned Swiss banks in a statement last week that they took the risk of being targeted and prosecuted if they didn't join the program.

The US Can Use Swiss Data for Enforcement Actions! The new agreement makes clear that “personal data provided by the Swiss banks… will be used and disclosed only for purposes of law enforcement (which may include regulatory action) in the United States or as otherwise permitted by US law.”

 

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Source:

Reuters

Israel No Longer a Tax Haven!

Moshe Asher: The Tax Authority plans to provide information to relevant countries about foreign residents' capital in Israel.

"We won't be a tax haven for foreign residents," said Israel Tax Authority director general Moshe Asher at the conference of the CPA Association of Jerusalem conference today December 17, 2013. 

He said that the Tax Authority planned to provide information to relevant countries about foreign residents' capital in Israel, and that these countries will reciprocate about the foreign assets of Israelis.

Asher said that foreign banks already provide information about Israeli citizens, under an expedited procedure at the Ministry of Justice. He advised relevant parties to Voluntarily Disclose information. 

This could be a result of efforts made by the US to crack down on US Citizen's with undeclared Israeli Bank Accounts. We discussed this crack down in our posts IRS Continues Cracks Down on Undeclared Israeli Bank Accounts! and More Tax Problems for U.S. Citizens with Foreign Bank Accounts in Israel.

  

Have unreported income from an Israeli Bank?

Felling a Bit Faclept?

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for a FREE Tax Consultation at: 

 www.TaxAid.us or www.TaxLaw.ms or

Toll Free at 888-8TaxAid (888 882-9243).

Source:

Globes'