Announcement 2006-95 _ IRB

Name

Address

ks~gnation

Date of Censure

Castiglione, John

Pittsf~eld,MA

Attorney

October 4, 2006

Shannon, Iames P.

Rochester, NH

At t ilrney

October 4, 2(M6

Kuller. Mark A.

Bethcsda. M D

Attorney

Oc~ober6, 2006

Resignations of Enrolled Agents
Under Title 3 1. Code o f Fedcral Regulat~uns.Part 10, an e~irollcdagent, In order to avoid the institution or conclusion
of a proceeding for his or her disbarnlet~t
or suspenzion from practice bcfclre the In-

tcmal Revenue Srrvice. may offer his or
her resignation as an enrolled agent. The
Director, Dff~ceof Professional Rcsponslbility, in his discretion, may accept the offrred restgnation.

The Director, ORice of Professional
Responsibility, has accepted offirs of resignation as an enrolled agent from the
following ~ndividuals:

Natnc

Address

Date of Resignation

Schwanz, Judy

Las Vegas, NV

Dctuber 13, 2006

Settlement Initiative for
Employees of Foreign
Embassies, Foreign Consular
Offices and International
Organizations in the United
States

the settlement procedures and Sectiotl 5
states how ineligible and non-participat-

ing taxpayers will be treated. TLlrpayers
have until February 20, 2007, to notify the
Service uf their intent lo participate in this
settlement uiitiative.
The IRS has determined that ;i significant nutnlrer of U.S. citizenz :~ndlawful
permanent residentc ("LPRs" also referred
to 11s "green cardholders") employrd at
Announcement 2006-95
foreign embassies, foreign consul;ir offices
and intert~ationalorg:~nizationsI ~ thc
I
Scction 1 . Overview and Purpose of the
U.S.
have
f21Ied
to
fulfill
their
U.S.
income
Settle~ncnt1nltiatrve
tax responstbilities. Some have failed to
'This annilu~~cernent
provides :I two-part t~melyfile U.S. tax returns. Others have
settlement initiative offered by the Inter- f,~iledto accurately report the tax due hy
nal Kcvenue Service {IRS) under which underreporting incntne, claiming deduccurrent and former employees of foreign tions for u~~allowable
expenses, and/or
etnbassies, foreign consular offices or l r i - failing lo pay s e l f - e n ~ p l o y ~ ~taxes.
~ c n t See
ternation;ll organizations (35 defined in Section 3 ~ of) this announcement for the
1 R r.3 7701(a)(18)) in the Crnited States
settlement term5 nf he income tax part of
(1J.S.jcan: ( I ) resolve income tax matters the settlement iniriiltive.
rCl,ltcd to their cmploytnent at n foreign
U.S. citizens and LPRs who perform
ernbass!, foreign coi~sularoffice or Inservicer i n the United States its cornmon
tcrnationnl organization; nnd ( 2 ) unwind law employees of t-nre~gn
guvernlnents are
their panlcipation in Simplified En~ploycc nor con~iderrdto be self-employed for purPcna~odInd~vidualRetirelnemt Account poses of 1.R.L'.
401 and 40& Tliesc in{SEPIIRA) plans, which they erroneously dividuals are rotnlnon law employees and,
zst,lblished. Section 2 describes eligi- thur. may nut contribute to SEPIIRA plans
h ~ l ~ trcyuirenients
y
to participate i n this bawd on their emplnymcnt with fnreign
settlcmrnt initiative. S r c t ~ o n3 describes e~nhasl;ics,foreign rlou.wlar offices and inthe set~leri~ent
terms. Sictioil 4 sets oul rernational urganizatlnns. Many U.S. citl-

December 11, 2006

zens and LPRs employed by foreign em-

bassies, foreign consular office5 and international organiza~ionshave erron~ously
establ~shedSEPflRA plans, claimed deductions for c o n ~ ~ i b u t i to
o ~the
~ s plans and
used the plans as part of thcir retirement
planning. See Section 3(b) of this announcement for the terms of the rettlement
uf the SEPnRA part uT the settlement initiative.
Section 2. Eligibility Requ~ren~ents
( 1) T h ~ settlement
s
initlatrve is limited
zu employees and former employccs of foreign embassie?. foreign consular offices
or international organizat~onswho are elther c u ~ ~ e n temployed
ly
ur were employed
as such in the United States. Thc in~tiatrve is limited to taxntwn issues relai~ng
to their employn~entat a forc~gnembassy,
foreign conwlar office or international organlzatlnn for taxable year:, 1003, 2004.
and 2005.
( 2 ) To bc elig~bleto part~cipate,l a x payers who contributcd tu SEPIIRA pli1n3
based on t h r ~ rcmploytnent w ~ t hforeign
etnbassic.r, foreign consuldr otlices and
intmmational wganizntlons, nluht comply,
where applicablr, with all requircmri~ts
of bat11 parts of t t ~ rsettlement in~rratltje
(Sections 3(;1) and 3(b))

2006-50 I.R.B.