I recently attended my annual tax conference in South Carolina. Tax practitioners from all over the country attended and shared their knowledge and expertise in emerging tax matters and areas of concern coming down the pipeline.
Two, I think, are most notable.
First, with FATCA now in play, see: Forbes Article, expect that your foreign bank accounts to be discovered by the IRS. The penalties are significant so seek professional help in becoming compliant! See: www.IRSFBARTAXHELP.com for more information.
Second, the IRS announced a new initiative and role for the IRS Office of Appeals called “AJAC”, or Appeals Judicial Approach and Culture. The highlights of the announcement are significant. Now, an IRS Appeals Officer assumes the role of a quasi-judicial law Judge, a truly independent judicial officer from IRS Examination and/or Collections. There is also a firm prohibition in Appeals now on the raising of “new” issues at Appeals. The Appeals Officer is to review and make an independent determination on the issues presented to him or her from IRS Exam and/or IRS Collections de novo. Any “new” issues raised will be sent back to Exam or Collections. Finally, and importantly, if you produced a Collection Information Statement, 433-A or 433-OIC, to Exam or Collections within 12 month of your Appeals Conference, Appeals cannot then demand NEW updated statements and financials. AJAC should motivate Appeals Officers to sit truly independent and rule on your tax issues upon the evidence, issues, and litigation hazards before him or her. The hope is that the days of “what’s in it for the government?” at IRS Appeals are behind us. See: Memorandum to IRS Appeals Officers.