IRS Waives Penalty for Tax Withholding & ES Payments for Taxpayers Who Fell Short in 2018

WASHINGTON — The Internal Revenue Service announced in Notice 2019-11, issued on January 16, 2019 that it is waiving the estimated tax penalty for many taxpayers whose 2018 federal income tax withholding and estimated tax payments fell short of their total tax liability for the year.

The IRS is generally waiving the penalty for any taxpayer who paid at least 85 percent of their total tax liability during the year through federal income tax withholding, quarterly estimated tax payments or a combination of the two. The usual percentage threshold is 90 percent to avoid a penalty.

The waiver computation announced today will be integrated into commercially-available tax software and reflected in the forthcoming revision of Form 2210 and instructions.

This relief is designed to help taxpayers who were unable to properly adjust their withholding and estimated tax payments to reflect an array of changes under the Tax Cuts and Jobs Act (TCJA), the far-reaching tax reform law enacted in December 2017. 

"We Realize There Were Many Changes That Affected People

Last Year and This Penalty Waiver Will Help Taxpayers Who Inadvertently Didn't Have Enough Tax Withheld,"

 

said IRS Commissioner Chuck Rettig.

“We urge people to check their withholding again this year to make sure they are having the right amount of tax withheld for 2019.”

The updated federal tax withholding tables, released in early 2018, largely reflected the lower tax rates and the increased standard deduction brought about by the new law. This generally meant taxpayers had less tax withheld in 2018 and saw more in their paychecks.

However, the withholding tables couldn’t fully factor in other changes, such as the suspension of dependency exemptions and reduced itemized deductions. As a result, some taxpayers could have paid too little tax during the year, if they did not submit a properly-revised W-4 withholding form to their employer or increase their estimated tax payments.

For waiver purposes only, today’s relief lowers the 90 percent threshold to 85 percent. This means that a taxpayer will not owe a penalty if they paid at least 85 percent of their total 2018 tax liability.

If the taxpayer paid less than 85 percent, then they are not eligible for the waiver and the penalty will be calculated as it normally would be, using the 90 percent threshold. For further details, see Notice 2019-11.

Although the IRS won’t begin processing 2018 returns until Jan. 28, software companies and tax professionals will be accepting and preparing returns before that date.

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IRS Employees Called Back for Tax Season Without Pay

On January 8, 2019 we posted IRS Confirms Tax Filing Season to Begin January 28, where we discussed that despite the government shutdown, the Internal Revenue Service confirmed on January 7, 2019 in IR-2019-01 that it will process tax returns beginning January 28, 2019 and provide refunds to taxpayers as scheduled.

The Treasury Department has now released a revised shutdown contingency plan on January 15, 2019 calling for more than 46,000 Internal Revenue Service employees to return to work to get ready for tax filing season, but the majority of them will be unpaid until the partial government shutdown ends.

Under the previous contingency plan that has been in place since the shutdown began on Dec. 22, 2018, 88 percent of the IRS’s 80,000 employees had been sent home without pay. Under the new filing season plan released Tuesday, 46,052 employees will be back on the job starting the week of January 14, 2019; 42.6 percent of the workforce will remain furloughed.

Last week, the IRS announced that tax refunds would be processed as usual once tax season begins on January 28th, even if the shutdown lasts until then, and said it would be recalling a “significant portion” of its furloughed employees. Since then, the IRS has brought back approximately 400 furloughed employees to process income verification forms for mortgage applications, but they are being paid out of the user fees for the applications.

The union representing IRS employees, the National Treasury Employees Union, is protesting the plan to call back workers without paying them.

The NTEU filed a lawsuit last week challenging the Trump administration’s plans, saying that the executive branch can’t continue to force more and more employees to show up in exchange for just an IOU. A federal judge on January 15th, denied the NTEU’s request for an immediate temporary restraining order. The next hearing in the case is scheduled for Jan. 31st.

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New GILTI and FDII International Tax Forms for 2018

International taxpayers will have to spend additional time on tax compliance with new forms for GILTI and FDII in 2018. 

 

The IRS recently issued Form 8992, U.S. Shareholder Calculation of Global Intangible Low-Taxed Income (GILTI) for U.S. shareholders to compute their GILTI inclusion.  IRC Sec. 951A requires U.S. shareholders of CFCs (controlled foreign corporations) to include in gross income GILTI (Global Intangible Low-Taxed Income) for the tax years of the CFCs.  This reporting begins after December 31, 2017.

In addition, the IRS issued Form 8993 Section 250 Deduction for Foreign-Derived Intangible Income (FDII) and Global Intangible Low-Taxed Income (GILTI) which taxpayers will use to determine their allowable deduction. New IRC Sec. 250 allows certain taxpayers to deduct an eligible percentage of FDII (Foreign-Derived Intangible Income) and GILTI.

New GILTI Form Is Final - New FDII Form Not Yet Final

The IRS has issued a new form, Form 8992, for doing the calculations with respect to Code Sec. 951A, which was enacted by the Tax Cuts and Jobs Act. Code Sec. 951A requires U.S. shareholders of controlled foreign corporations to include in gross income the shareholder's global intangible low-taxed income. 

 

Only draft versions of the new FDII form and instructions are available for viewing at the IRS website. The IRS cautions taxpayers that the forms remain subject to change and require approval by the OMB (Office of Management and Budget) before final versions will be officially released.

Determining Who Must File Under IRC Sec. 951A & IRC Sec. 250

Form 8992 U.S. Shareholder Calculation of Global Intangible Low-Taxed Income (GILTI) must be filed by any U.S. shareholder of one or more CFCs that must take into account its pro rata share of the CFCs tested income or tested loss in determining the U.S. shareholder’s GILTI inclusion under IRC Sec. 951A. This amount is taken from a CFC’s Form 5471, Schedule I-1.

For purposes of Form 8992:

• A U.S. shareholder is a U.S. person that directly, indirectly, or constructively owns (within the meaning of IRC Sec. 958) at least 10% of the total value of shares of all classes of a CFC’s stock, or at least 10% of the total combined voting power of a CFC’s voting class stock; and,
• a CFC is a foreign corporation with U.S. shareholders that directly, indirectly, or constructively own (within the meaning of IRC Sec. 958) on any day of the foreign corporation’s tax year more than 50% of the total value of the corporation’s stock, or the total combined voting power of all of its voting stock classes.

Form 8993 Section 250 Deduction for Foreign-Derived Intangible Income (FDII) and Global Intangible Low-Taxed Income (GILTI) must be filed by all domestic corporations in order to determine the eligible deduction for FDII and GILTI allowed under IRC Sec. 250. The deduction is only available to domestic corporations (not including REITs (Real Estate Investment Trusts) or RICs (Regulated Invested Companies) and S corporations. The GILTI and FDII deductions from Form 8993 will also be entered on Form 1120, Schedule C.

Where and When to File

Both Forms 8992 and 8993 must be attached to the taxpayer’s income tax return and filed by the due date of the income tax return (including extensions). Any corrections to these forms may be included with an amended return.

Need International IRS Advice? 

 

   

Contact the Tax Lawyers at 

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IRS Issues Updated New Form 5471 – What's New?

 On January 2, 2019 the IRS updated its webpage entitled Instructions for Form 5471 (12/2018) where it lays out the numerous changes caused by the TCJA of 2017, which have now been incorporated into the updated form. 

•  On December 22, 2017, Congress enacted the "Tax Cuts and Jobs Act," P.L. 115-97 (the "Act").
• Act section 14101 enacted section 245A. Section 245A(e)(2) provides for a new subpart F inclusion for income from hybrid dividends of tiered corporations. As a result, new line 1b was added to Schedule I. See the instructions for Schedule I, line 1b for additional information. Also, as a result of Act section 14101(e), new lines 9 and 22 were added to separate Schedule M.
• Act section 14102(c)(1) added section 964(e)(4), which provides for a new subpart F inclusion for dividend income from the sale of stock of a lower-tier foreign corporation. As a result, new line 1a was added to Schedule I. See the instructions for Schedule I, line 1a for additional information.
• Act section 14103 amended section 965 to require certain taxpayers to include in income an amount (section 965(a) inclusion amount) based on the accumulated post-1986 deferred foreign income of certain foreign corporations that they own either directly or indirectly through other entities.
• Act section 14201(a) enacted section 951A. This new code section requires U.S. shareholders of controlled foreign corporations (CFCs) to report the inclusion of global intangible low-taxed income (GILTI) for years in which they are U.S. shareholders of CFCs. Section 951A is effective for tax years of foreign corporations beginning after December 31, 2017, and to tax years of U.S. shareholders in which or with which such tax years of foreign corporations end. Use Form 8992, U.S. Shareholder Calculation of Global Intangible Low-Taxed income, to figure a U.S. shareholder’s GILTI inclusion. Also complete separate Schedule I-1 (Form 5471) to report information determined at the CFC level with respect to amounts used on Form 8992 in the determination of a U.S. shareholder's GILTI inclusion.
• Act section 14201(b)(2)(A) amended section 904(d)(1) by adding a new foreign tax credit limitation separate category for section 951A income. As a result, Schedules, E, J, and P, for example, may be completed for this new separate category, if applicable.
• Act section 14202 enacted section 250, which allows certain domestic corporations a deduction for the eligible percentage of foreign-derived intangible income (FDII) and GILTI. Section 250 is effective for tax years beginning after December 31, 2017. Use Form 8993, Section 250 Deduction for Foreign-Derived Intangible Income (FDII) and Global Intangible Low-Taxed Income (GILTI), to figure this deduction. 
• Act section 14211 amended section 954(a) to eliminate foreign base company oil related income from the calculation of foreign base company income. As a result, Worksheet A and instructions were modified.
• Act section 14212 repealed the section 955 subpart F inclusion based on withdrawal of previously excluded subpart F income from qualified investment. As a result, old line 3 of Schedule I was deleted. Also, old Worksheet C and instructions were deleted. Also note that old Worksheet D is now Worksheet C.
• Act section 14214 amended section 951(b) to modify the definition of U.S. shareholder, and Act section 14213 amended section 958(b) to modify attribution rules applicable for determining whether a U.S. person is a U.S. shareholder and whether a foreign corporation is a CFC.
• Act section 14215 amended section 951(a)(1) by eliminating the requirement that a CFC must be controlled for 30 days before subpart F inclusions apply. As a result, the definition of Category 5 filer has been amended.
• Act section 14222 enacted section 267A. Under section 267A, a deduction for certain interest or royalty paid or accrued to a related party pursuant to a hybrid transaction or by, or to, a hybrid entity may be disallowed to the extent the related party, under its tax laws, does not include the amount in income or is allowed a deduction with respect to the amount.
• Act section 14301 repealed section 902 (deemed paid credits with respect to dividends) and amended section 960 (deemed paid credits for subpart F inclusions and GILTI inclusions). As a result, we amended Schedules E and J, and related instructions.
• Act section 14401 enacted section 59A, Tax on Base Erosion Payments of Taxpayers with Substantial Gross Receipts. The new section 59A imposes on each applicable taxpayer a tax equal to the base erosion minimum tax amount for the tax year. Section 59A applies to base erosion payments paid or accrued in tax years beginning after December 31, 2017.

Form 5471 Changes 

1. Category 1 (previously reserved) is now used by U.S. shareholders of specified foreign corporations (SFCs) subject to the provisions of section 965.
2. Schedule B, Part II, is new. It is used to provide information about direct shareholders of the foreign corporation. For details, see specific instructions for Schedule B, Part II, later.
3. Schedule C, lines 8a and 8b are new. These lines are used to report foreign currency transaction gain or loss. Lines 19 through 24 are either new or reworded to reflect updated GAAP rules.
4. Schedule F, lines 3 and 17 are new. They are used to report derivatives. They were added to reflect the rules of Act section 14103 (specifically, derivatives are considered cash for section 965 purposes).
5. Schedule G, lines 4, 5, and 6 are new. These lines are used to answer questions about base erosion payments and benefits under section 59A, interest or royalty amounts paid or accrued for which the deduction is disallowed under section 267A, and foreign-derived intangible income deductions under section 250. These lines were added to reflect Act sections 14401, 14222, and 14202, respectively.
6. Schedule G, lines 9, 10, 11, and 12 are new. These lines are used to answer questions about cost sharing arrangements. These lines were added to reflect Regulations section 1.482-7.
7. Schedule G, line 13 is new. This line is used to answer a question about triangular reorganizations within the meaning of Regulations section 1.358-6(b)(2).
8. Schedule G, lines 14a and 14b are new. These lines are used to answer questions about transfers of intangibles. These lines were added to reflect section 367(d).
9. Schedule G, line 15 is new. This line is used to answer a question about whether the foreign corporation is an expatriated foreign subsidiary under Regulations section 1.7874-12(a)(9).
10. Schedule G, line 19 is new. It refers filers to a series of questions in the instructions for line 19. For each question for which the answer is “Yes,” the filer is required to enter the corresponding code from the instructions and attach a statement.
11. Schedule I, line 1a is new. This line is used to report section 964(e)(4) subpart F dividend income inclusions. Line 1a was added to reflect Act section 14102(c)(1).
12. Schedule I, line 1b is new. This line is used to report section 245A(e)(2) subpart F income inclusions. Line 1b was added to reflect Act section 14101(a).
13. Old line 3 of Schedule I was deleted to reflect the repeal of the section 955 subpart F inclusion. This line was deleted to reflect Act section 14212.
14. Schedules E and H are now separate schedules (no longer part of the base Form 5471) because these schedules must now be completed separately for each applicable category of income. New lines a and b have been added to these schedules to identify the category of income for which a given Schedule E or H is being completed. Furthermore, these schedules have been expanded as explained below.
15. Separate Schedule E has been expanded to request information pertaining to taxes for which a foreign tax credit is allowed and taxes for which a credit may not be taken. Furthermore, the schedule includes new Schedule E-1, which is used to report the current year changes in the cumulative balances of foreign income taxes paid or accrued by the CFC. For details, see specific instructions for Schedule E, later.
16. Separate Schedule H, line 2h is new. Line 2h is used to report foreign currency gains or losses.
17. Separate Schedule I-1 is new. It is used to report information with respect to amounts used in the determination of GILTI inclusions by U.S. shareholders under section 951A. For details, see specific instructions for Schedule I-1, later.
18. Separate Schedule J was expanded so that it also can be used to report accumulated E&P balances with respect to categories of previously taxed E&P resulting from the new types of income added by the Act (such as section 965(a) inclusions and GILTI inclusions).
19. Separate Schedule M, lines 9 and 22 are new. They are used to report hybrid dividends received and paid. These lines were added to reflect Act section 14101 (e). Lines 27 and 29 are also new. They are used to report accounts payable and accounts receivable.
20. Separate Schedule P is new. It is used to report previously taxed E&P of the U.S. shareholder of a CFC or SFC (see Category 1 Filer, below, for a definition of SFC). For more information, see the specific instructions for Schedule P, later.
21. Certain schedules must be completed separately for each applicable category of income. They are Schedules E, H, I-1, J, and P.
22. Note that Schedule M continues to be completed separately for each CFC.

 

Need International Tax Advice for Your Form 5471?

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IRS Confirms Tax Filing Season to Begin January 28

Despite the government shutdown, the Internal Revenue Service confirmed on January 7, 2019 in IR-2019-01 that it will process tax returns beginning January 28, 2019 and provide refunds to taxpayers as scheduled.

“We are committed to ensuring that taxpayers receive their refunds notwithstanding the government shutdown.

 

 

I appreciate the hard work of the employees and their commitment to the taxpayers during this period,”

said IRS Commissioner Chuck Rettig.

Congress directed the payment of all tax refunds through a permanent, indefinite appropriation (31 U.S.C. 1324), and the IRS has consistently been of the view that it has authority to pay refunds despite a lapse in annual appropriations. Although in 2011 the Office of Management and Budget (OMB) directed the IRS not to pay refunds during a lapse, OMB has reviewed the relevant law at Treasury’s request and concluded that IRS may pay tax refunds during a lapse.

 The IRS will be recalling a significant portion of its workforce, currently furloughed as part of the government shutdown,

to work.

Additional details for the IRS filing season will be included in an updated FY2019 Lapsed Appropriations Contingency Plan to be released publicly in the coming days.

“IRS employees have been hard at work over the past year to implement the biggest tax law changes the nation has seen in more than 30 years,” said Rettig.

As in past years, the IRS will begin accepting and processing individual tax returns once the filing season begins. For taxpayers who usually file early in the year and have all of the needed documentation, there is no need to wait to file. They should file when they are ready to submit a complete and accurate tax return.

The filing deadline to submit 2018 tax returns is Monday, April 15, 2019 for most taxpayers. Because of the Patriots’ Day holiday on April 15 in Maine and Massachusetts and the Emancipation Day holiday on April 16 in the District of Columbia, taxpayers who live in Maine or Massachusetts have until April 17, 2019 to file their returns.

Software companies and tax professionals will be accepting and preparing tax returns before Jan. 28 and then will submit the returns when the IRS systems open later this month. The IRS strongly encourages people to file their tax returns electronically to minimize errors and for faster refunds.

Have a Tax Problem?  

 



 

 

Contact the Tax Lawyers at

Marini & Associates, P.A.

 

 for a FREE Tax Consultation Contact US at

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

 

 

 

 

No Relief Expected for US Citizens Living Abroad

According to Moodys Gartner, in the middle of the perfect storm on Capitol Hill created by the change in control of the House of Representatives back to the Democratic party, the government shutdown, and President Trump’s border wall funding demands, a bill was introduced on December 20, 2018 that would “amend the Internal Revenue Code of 1986 to provide an alternative exclusion for nonresident citizens of the United States living abroad.”

Specifically, H.R. 7358 (the “Tax Fairness for Americans Abroad Act of 2018” or “the Bill”) seeks to essentially replace the current citizenship-based taxation system with a more residence-based taxation system for “qualified nonresident” U.S. citizens. While many dual citizens or U.S. citizens residing in Canada may meet the proposed definition of “qualified nonresident citizen” under the Bill – more on this below –  it might be helpful to first put the Bill in historical context to understand the likelihood of such ground-breaking legislation becoming U.S. law.

 

The likelihood of the Bill getting any attention in 2019 by the Democrats is slim given their expected legislative agenda and proposed oversight investigations on President Trump.

 

For US citizens living abroad who are not compliant with their US tax affairs, we would strongly urge such people not to rest easy and assume that this proposed bill will provide them with an easy answer.

Noncompliant Americans living abroad should consult with experienced Tax Attorneys to help them get right with the IRS, while there are still "Programs" to help them file delinquent tax returns, without any tax penalties for non-US Domiciliary's.

 

Are You a US Citizen Who Has Not Filed 

Any Tax Returns in Many Years?

 

 

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Ct of Claims Rules That Failure to Properly Review Tax Return Results in Maximum Willful Fbar Penalty

According to Law360, the U.S. Court of Federal Claims has upheld the full amount of civil penalties tied to a woman’s undisclosed offshore account, rejecting the reasoning in two recent cases where the judges found that a decades-old penalty cap was still intact.

U.S. Claims Court Judge Susan G. Braden ruled against Alice Kimble in her refund suit seeking the nearly $700,000 in civil penalties she paid after the Internal Revenue Service concluded she willfully failed to disclose a Swiss account on a 2007 foreign bank and financial accounts form, or FBAR.

The amount was calculated under 31 U.S.C. Section 5321 , which Congress had amended in 2004 to say that willful violations of FBAR requirements can lead to a penalty that is either $100,000 or 50 percent of the balance in the foreign account, whichever is more. In weighing Kimble’s penalty assessment, Judge Braden acknowledged two recent federal court cases where the judges ruled that the statute change in 2004 didn’t cancel out a 1987 regulation that caps penalties at $100,000.

But in her late December opinion, Judge Braden found that the reasoning in those decisions, issued in Texas in May and Colorado in July, conflicts with a decision issued by the Federal Circuit in 1997.

In that case, Barseback Kraft AB v. United States, nuclear energy companies argued that because the U.S. Department of Energy had authority to price uranium when the parties entered into contracts, the DOE’s pricing system was still intact even though Congress later moved that authority to another agency. However, the Federal Circuit had disagreed, ruling the fact that the DOE’s pricing regulations hadn’t been formally withdrawn “did not save them from invalidity.”

Judge Braden cited the Barseback Kraft AB case in her Dec. 27 opinion, where she granted the U.S. government’s motion for summary judgment. In doing so, she found that the IRS didn’t abuse its discretion in assessing a civil penalty against Kimble that amounted to 50 percent of her UBS account.

“Like the legislation that stripped DOE of authority over uranium pricing, the Jobs Creation Act replaced the prior penalty for willful violations of federal tax law in [31 U.S.C. Section 5321], thereby nullifying any inconsistent regulations governing the pre-2004 statute,” Judge Braden wrote.

 

Kimble’s case is not the first dispute where a claims court judge has rejected the reasoning in the Colorado and Texas cases. In late July, U.S. Claims Court Judge Edward J. Damich sided with the government in a separate penalty refund suit that cited the Texas ruling. His decision is now on appeal before the Federal Circuit.

In addition to the penalty assessment, the question of whether Kimble had willfully skirted her FBAR reporting requirements was also at issue before the Claims Court.

The government in June had contended that Kimble had “recklessly disregarded” her requirement to file a 2007 FBAR for her UBS account, which had been opened by her parents prior to 1980. As the government saw it, Kimble’s “undisputed actions demonstrate her clear intent to conceal the account from U.S. authorities,” including referring to the account by a number instead of her name and failing to tell her accountant about it.

Kimble hit back the following month, contending that the government’s interpretation of 31 U.S.C. Section 5321 would render the term “willful” meaningless, because under that reading, every person who fails to file a FBAR does so willfully.

She also claimed she wasn’t aware she had a legal duty to report her foreign bank accounts to the IRS until 2008 and therefore didn’t make a conscious choice not to comply.

 

But Judge Braden was not swayed, pointing to the case’s stipulated facts, including that Kimble didn’t review her individual income tax returns for accuracy between 2003 and 2008. In addition, Judge Braden noted that Kimble falsely represented on her 2007 income tax return that she had no foreign bank accounts. 

 

According to the opinion, these two stipulations “together evidence conduct by plaintiff, as a co-owner of the UBS account that exhibited a ‘reckless disregard’ of the legal duty under federal tax law to report foreign bank accounts to the IRS by filing a FBAR.”

According to the opinion, Kimble in 2009 was accepted into the IRS’ Offshore Voluntary Disclosure Program but withdrew in 2013, testifying that she decided to “take her chances” with the agency.
 

James O. Druker of Kase & Druker, who is representing Kimble, said in an email to Law360 on Wednesday that “it is unfathomable to me and many of my colleagues that a school teacher who voluntarily reported her previous failure to report the offshore account that was inherited from her parents and which she never touched, could receive the same 50 percent penalty that is imposed on criminals who are convicted of egregious tax fraud.” 

This case basically accepted that a taxpayer who had checked ‘no’ to the foreign account question on her income tax return and who knew she had a foreign account was subject to the willfulness penalty for failing to report the account on an FBAR regardless of actual knowledge of the FBAR filing requirement. While there were other bad facts for the taxpayer in this case, the Court appears to decided that it would have ruled the same way without those other bad facts. 

This trend increases the risk that most FBAR failures to report will be considered automatically willful, when the taxpayer otherwise filed an income tax report, absent special facts such as lack of knowledge of the account itself or perhaps contrary tax advice, which is a highly unfavorable trend for taxpayers.

 

The case is Kimble v. USA, case number 1:17-cv-00421, in the U.S. Court of Federal Claims.

 

 

Have Undeclared Income from an Offshore Bank Account?

 

 

Been Assessed a 50% Willful FBAR Penalty?

 

 

Contact the Tax Lawyers at 

Marini& Associates, P.A. 

 

 

for a FREE Tax Consultation

at: www.TaxAid.com or www.OVDPLaw.com or

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