OVDP offered taxpayers whose conduct was considered “willful” as to the nonreporting of foreign income with a path to compliance and more importantly an opportunity to diminish the threat of criminal charges they may face upon discovery by the IRS.
IRS and Department of Treasury provided operational rules for 2016 that allow at least for the 2016 tax year an extension of time for taxpayers to make the election on or before December 31, 2017 to treat R&E tax credits as a Payroll Tax Credit and claim the benefit against the next payroll tax filing.
As we have argued in our previous articles, as the world has globalized and commerce crosses borders more frequently, the current US corporate income tax code is not only obsolete it is suicidal. The time for change is overdue. But what change will we find under President-Elect Trump?
It may come as an unpleasant surprise to some readers to discover the Internal Revenue Service (“IRS”) has been using tax audits as cover for criminal investigations, which can directly relate to the tax issues or to some other federal matter.