Tax Strategies Flashcards

Within how many days must a business file Form 8300 after receiving more than $10,000 in cash in one or related transactions?

Answer: 15 days

IRC Section 6050I requires Form 8300 to be filed within 15 days of receiving the cash.

Breaking up cash deposits into amounts under $10,000 to avoid bank reporting is illegal under 31 U.S.C. 5324 even if what is true?

Answer: The funds were from lawful sources

Structuring is a crime regardless of whether the underlying funds are legitimate.

A U.S. person must file an FBAR when the aggregate value of foreign financial accounts exceeds what amount at any time during the year?

Answer: $10,000

FinCEN Form 114 is required when aggregate foreign account balances exceed $10,000 at any point in the year.

Under IRC Section 6672, the Trust Fund Recovery Penalty can be imposed on responsible persons for what percentage of unpaid trust fund taxes?

Answer: 100%

Section 6672 imposes a penalty equal to 100% of unpaid withheld employment taxes on willful responsible persons.

The IRS Whistleblower Program under Section 7623(b) generally awards what share of collected proceeds?

Answer: 15% to 30%

Qualifying whistleblowers may receive 15% to 30% of collected proceeds in cases exceeding the statutory thresholds.

A forensic accountant hired by a taxpayer's attorney to help the attorney understand financial data may be protected by which privilege arrangement?

Answer: Kovel arrangement

Under United States v. Kovel (1961), an accountant assisting counsel can fall under attorney-client privilege.

Why is the Section 7525 federally authorized tax practitioner privilege of limited value in fraud investigations?

Answer: It does not apply to criminal tax matters

Section 7525 privilege applies only in noncriminal tax matters, so it offers no protection in criminal proceedings.