NYA Stakeholder Liaison Field
IMRS Monthly Discussion Call Summary February 15, 2017
Carl Young, IRS
Brenda Luke, IRS
Norma Boyce, E.A.
Carol Romeril, E.A. Lauren Jarvi, E.A.
Paul Ziems, E.A.
Phyllis Jo Kubey, E.A.
Eunice A. Malkasian, E.A.
Tom O’Connor, E.A.
Cheryl Morse, E.A.
Dave LaRochelle, E.A.
Joy Palazzola, E.A.
John Apisa, CPA
Joyce Mohr, E.A.
Dave Locker, E.A.
Today’s Presentations slides:
IMRS Discussion Call February 15 2017 slide
Confusing FBAR Filing Requirements
The information and link below is to an IRS webpage that compares the form 8938 and FBAR requirements.
“Aggregate value of financial accounts exceeds $10,000 at any time during the calendar year. This is a cumulative balance, meaning if you have a combined account balance of $12,000 at any one time (but divided between 2 accounts), both accounts would have to be reported”.
Practitioners believe this is misleading. It should use $10,001 instead of $12,000. Someone with 2 accounts that totals $11,000 might think they don’t have to file- based on that webpage practitioners would say they got a legit argument. Practitioners know better but the general public is not so educated.
Does the IRS web page need to be clarified?
IMRS Team Response:
The point that the content owner (which is LB&I not SB/SE) is trying to make is that the U.S. person needs to look at all their foreign accounts owned and when the aggregate value of all the accounts (not an individual acct) exceed $10K at any time during the calendar year, an FBAR filing requirement is triggered. Could the point have been made (and clearer) using $10,001 in the example, probably……but it’s not wrong as is.
The SB/SE owned FBAR webpages are currently being updated on IRS.gov (the filing due date and extension process has changed), and we will advise the LB&I content owner for that page is, remind them that they need to update their page for the new due date, etc…….and let them know that we’ve received some concerns about that particular example.
W-2 Verification Code Test
Practitioners have noted some problems reading the verification codes specifically zeros and capital letter O.
IMRS Team Response:
The 16 digit verification code is comprised of capital letters A thru F and numbers zero (0) thru 9. The specifications for that field indicate that the Letter “O” can never be used. Anything that looks like an “O” is really a
zero. For the purposes of the test, omitted and incorrect W-2 Verification Codes will not delay the processing of a tax return.
UPDATE: eService Accounts Now Suspended:
The e-Services accounts for users who failed to verify their identities with the IRS have had their accounts suspended. The IRS mailed letters 5903 between December 1 and December 16 to those users who had been active on their accounts in the past year and who had access to the Transcript Delivery System. Users were given 30 days to verify their identities as part of our effort to better secure the e-Services program and protect taxpayer data.
We have updated the www.irs.gov/eservices landing page and the Important Update about Your e-Services Account to provide users with guidance about how to reinstate their accounts if they failed to do so within the 30-day timeframe. Please share this information with your teams and stakeholders.
IRS Selects New Advisory Council Members
The Internal Revenue Service announced the selection of five new members to the Internal Revenue Service Advisory Council (IRSAC) including Phyllis Jo Kubey. The IRSAC provides an organized public forum for IRS officials and representatives of the public to discuss key tax administration issues. The IRSAC, established in 1953, selects members to represent the taxpaying public, tax professionals, small and large businesses, academia and the payroll community. The council provides the IRS Commissioner and division leadership with important feedback, observations and suggestions. Phyllis Jo Kubey is the owner of Phyllis Jo Kubey, EA, CFP, ATA, ATP, Tax Preparation & Consultation in New York and has 30 years of experience in taxation.
Executive Order Policy Question
Practitioner asked a question about the IRS policy that she read about in the press about response to new Executive Order where tax returns are not now being automatically rejected if silent on ACA compliance.
The instruction for individual taxpayers involving the Affordable Care Act has been to indicate on their Form 1040 filing whether they had health insurance, an exemption from coverage or made a shared responsibility payment. In recent years, tax returns silent in that regard were still processed. This year, the IRS put in place system changes that would reject tax returns during processing in instances where the taxpayer didn’t provide that information.
The recent executive order directed federal agencies to exercise authority and discretion available to them to reduce potential burden. Consistent with that, the IRS has decided to make changes that would continue to allow electronic and paper returns to be accepted for processing in instances where a taxpayer doesn’t indicate their coverage status.
However, legislative provisions of the ACA law are still in force until changed by the Congress, and taxpayers remain required to follow the law and pay what they may owe.
Processing silent returns means that taxpayer returns are not systemically rejected, allowing them to be processed and minimizing burden on taxpayers, including those expecting a refund. When the IRS has questions about a tax return, taxpayers may receive follow-up questions and correspondence at a future date, after the filing process is completed. This is similar to how we handled this in previous years, and this reflects the normal IRS post-filing compliance procedures that we follow.
The IRS continues to work closely with the software industry on this issue.
2017 IMRS Monthly Discussion Call Schedule
NYA IMRS Monthly Discussion Calls will be held on the Third Wednesday of the month. Please note that to accommodate the holiday season the December 2017 meeting will be held on December 13th.
Schedule for remainder of year:
NYA IMRS Discussion Calls will be held on the third Wednesday of the month.
Schedule for remainder of year:
• March 15th
• April 19th
• May 17th
• June 21st
• July 19th
• August 16th
• September 20th
• October 18th
• November 15th
• *December 13th
Next month’s IMRS Discussion Group Call will held on Wednesday March 15th at 10:00 a.m. Please note that the meeting will be held using WebEx Internet conferencing technology. As usual, I will send out an invitation with log-in instructions a couple of days prior to the event.
Thanks to all for taking the time to attend this month’s call.
Internal Revenue Service
15 New Sudbury Street
JFK Federal Building Stop 21300
Boston, MA 02203-0208