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Million-dollar overpayments made by various ministries, public agencies highlighted in sampled audit by Auditor-General Office amongst various lapses

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The Auditor-General Office (AGO) earlier released its audit report for the financial year 2020/21 on 22 July, which flagged a number of lapses in payments made by various ministries and public agencies.

In its report, AGO stated that it aims to “audit and report to the President and Parliament on the proper accounting and use of public resources so as to enhance public accountability and help strengthen the financial governance of the public service”.

Here are some of the key lapses and overpayments uncovered in the report.

AGO found “tell-tale signs” on MCCY supporting documents, overpayment of S$792

AGO found “tell-tale signs” on supporting documents provided by the Ministry of Culture, Community and Youth (MCCY), which indicated that some records could have been photocopies with alterations made to the dates and duration of services rendered.

Its test checks on 10 claims – which amounted to S$1,812 – made between April 2019 and March 2020 found that 6 of the 10 softcopy attendance records provided as supporting documents contained tell-tale signs.

Similar tell-tale signs of pre-printed signatures were also found on 151 claim forms totalling S$7,248.

AGO also noted that there were no supporting documents for 46 claims amounting to S$4,872, and no evidence of checks made by the Payment Verifying Officer on 41 attendance records and 210 claim forms for 251 claims amounting to S$15,060.

It also found duplicates or incorrect payments for 17 claims, which resulted in an overpayment of S$792.

AGO found S$84,300 in overpayment by MINDEF

According to AGO, the Ministry of Defence (MINDEF) has entered into a 10-year contract with a national healthcare institution in October 2018, with the annual contract valued at S$8.91 million.

It found that an overpayment of 323 bills totalling S$84,300 was made between 30 September 2019 to 18 March 2021, which had occurred due to the healthcare institution incorrectly billed MINDEF at the private non-subsidised rate.

MINDEF informed AGO that the billing error had occurred because the staff at the healthcare institution had wrongly removed the government subsidy for the two tests during a fee review on 28 September 2019.

The ministry also argued that it was difficult to verify whether the prices charged were correct as the healthcare institution did not give MINDEF the pricing rate for tests not found in the contact list.

MINDEF said it would complete the recovery of overpayment from the healthcare institution by July this year.

An overpayment of S$494,600 by Public Service Division

The Public Service Division (PSD), which is listed under the Prime Minister’s Office (PMO) section, is the policy owner for medical and dental benefits for the Civil Service.

PSD works with the Accountant-General’s Department (AGD) to administer medical and dental benefits for officers/pensioners and their eligible dependents.

According to AGO, there were 3 million medical and dental claims processed for 177,190 officers/pensioners and their dependents from 1 January 2018 to March 2020, with the total government expenditure on these claims amounted to S$463.58 million.

It noted that the total Medisave contributions made by the government under the civil service medical benefits framework during the same period was S$316.25 million.

AGO found that 2,405 possible claims were incorrectly paid to 705 ineligible officers/pensioners and their dependents because their medical benefits entitlement records in the IT systems were outdated, which resulted in S$208,400 of the government expenditure on these claims.

The audit findings also revealed that 184 officers were wrongly paid a total of S$194,500 in Medisave contributions during the period of 1 January 2018 to 31 March 2020, even though they were not eligible for Medisave contributions.

AGO went on to note that 5,231 claims totalling S$99,800 were incorrectly reimbursed to officers/pensioners as those were claims for expenses incurred at entities that were not on the list of approved medical institutions for claims.

It also found indications of possible duplicate claims, split claims and bypassing of dental claim rules during the period of 1 January 2018 to 31 March 2020, in which the government expenditure for the 1,914 claims amounted to S$48,300.

 

Based on the table above, the estimated net possible overpayment from 1 January 2018 to 31 March 2020 amounted to S$495,400, but given there were claims which fell under more than one category of audit observations, AGO said the estimated figure is S$494,600.

Overall, AGO’s audit found around 9,500 possible erroneous payments for medical and dental benefits.

“While this amounted to only 0.3 per cent of the total 3 million claims processed for the period audited, the estimated possible overpayment by the government is not small, at around S$0.50 million,” it highlighted.

AGO flagged tendering issues by NLB

AGO found lapses at various stages in the National Library Board’s (NLB) procurement of a digital film projection system worth S$4.75 million, noting that there was “inadequate assurances” that principles of value for money, fairness and transparency had been adhered to.

It noted that the NLB had discussed its requirements with a company related to the awarded tenderer eight months before the tender was published, during which the said company submitted several budgetary quotes to NLB.

NLB claimed that it had requested a budgetary quote from another company but did not receive any response.

Nevertheless, AGO said NLB has failed to provide any documentary evidence to substantiate this.

It also highlighted that NLB had worked with the awarded tenderer prior to the publication of tender, to develop the tender specifications for one of the tender items, with the approved procurement amounted to S$0.19 million.

Eight potential tenderers had attended the tender briefing conducted by NLB. But AGO discovered that NLB did not share with the other potential tenderers its clarification relating to costing information.

Of the three bids received at the close of tender, only one qualifying bid by the awarded tenderer was evaluated, which was deemed reasonable by NLB based on comparison with the Estimated Procurement Value (EPV).

AGO said it was “a self-to-self” comparison because about 52 per cent of the EPV was derived based on a budgetary quote from the related company of the awarded tenderer, while another 45 per cent was based on NLB’s own cost estimates which cannot be substantiated.

“There was also no assessment conducted on the reasonableness of the maintenance costs (ranging from S$133,594 for the second year to S$310,728 for the fifth year),” said AGO, noting that there was a 44 per cent increase in the maintenance costs.

AGO found serious lapses in the People’s Association

AGO found lapses in the management of contract variations for two development projects worth S$623.96 million, which indicated “weaknesses in the monitoring of contract variations” and “inadequate oversight of the consultants” by the People’s Association (PA).

“The high number of cases with no evidence of approval also pointed to poor documentary trails, which increased the risk of irregularities not being detected,” AGO said.

It highlighted that the lack of independent sources to assess the cost reasonableness of star rate items and the failure to properly account for variation works also did not provide assurance that PA had obtained full value for the public funds spent.

AGO did a sampling test and found lapses in 252 variations out of the 465 contract variations it checked, which amounted to $13.62 million. These lapses include:

  • No evidence of approval for the 109 out of 465 contract variations, amounting to $8.06 million.
  • Approvals for 142 out of 356 contract variations amounting to $5.44 million were obtained from the approving authority 1 month to 5.5 years after works had commenced or were already completed.
  • No evidence that approval was sought for the increase in variation cost for six contract variations from the total approved amount of about $500 to $800K. The increase for each variation ranged from 21.6 per cent to 226.6 per cent.

AGO also found that assessments of cost reasonableness of star rate items totalling S$1.26 million were not based on independent sources for 8 out of 14 contract variations it test-checked.

There was an estimated overpayment of $621,700 and underpayment of S$161,600, it added, as AGO found 26 instances of variation works items in 10 contract variations with lapses.

It also found two instances where the contract was not adjusted to account for contract variations, which involved works that were not carried out in accordance with contractual provisions. The estimated overpayments amounted to S$279,300.

Possible irregularities in documents relating to payments

According to the report, PA had engaged contractors to carry out minor building works at the facility with the contract value amounted to S$6.50 million, and also engaged a managing agent to assist it in managing the facility.

For star rate items, three quotations were to be obtained to assess price reasonableness.

However, AGO discovered possible irregularities in the supporting documents for 34 payments – which amounted to S$1.17 million – out of the 36 payments it test-checked, of which each involved one or more star rate items.

“The possible irregularities include possible falsification of quotations, alteration of hardcopy payment supporting documents and creation and backdating of documents to give the false impression that proper processes had been followed,” said AGO.

Furthermore, AGO’s test check of the same 36 payments revealed other possible lapses and irregularities in 35 payments totalling S$1.26 million:

  • Splitting of Purchase Orders (POs);
  • Works carried out before issuance of POs;
  • Winning quotations approved by PA officers retrospectively;
  • Star rate items formed bulk of payment and possible inflation of the price of star rate items; and
  • Inappropriate use of contract rates and/or inflated quantities.

AGO flagged tendering issue involving Singapore Polytechnic

AGO noted that Singapore Polytechnic (SP) did not put up required reports to the central government authority concerning two tenderers who had withdrawn their bids – total approved procurement valued at S$0.57 million – after the close of tenders, but before the tenders were awarded.

The two tenderers had submitted the lowest tender bid for the respective tenders. For the first case, the tenderer’s bid price was 33 per cent lower than the next lowest bid.

For the second case, the tenderer’s bid price was 15 per cent lower than the next lowest bid.

AGO said the two tenderers had requested to withdraw their bids 7 days and 35 days respectively after the close of tenders, with the reasons that they had erroneously underquoted the bids.

“Withdrawal of tenders after the close of tender but before the tender award is a serious matter and a ground for debarment of tenderers,” it stated.

Audit findings also revealed that one of the two tenderers was subsequently awarded government tenders totalling S$2.40 million by four public sector entities – including SP – within a period of about one year after its withdrawal.

For the subsequent tender – approved procurement value of S$0.40 million – that SP awarded to the tenderer who had previously withdrawn the bid, AGO noted that the submission to SP’s Tender Approving Authority did not mention the fact that the tenderer had withdrawn its previous tender bid to SP.

“There was thus no full disclosure of information to the Tender Approving Authority,” it added.

AGO found 341,208 fitness trackers worth over S$5mil left unused by HPB

During its checks, AGO found that about 268,191 excess fitness trackers bought for the National Steps Challenge (NSC) were not put to use even though the seasons had ended between one and five years earlier.

The trackers were given free to eligible participants who signed up for the challenge to encourage people to exercise more. Each tracker cost between S$10.38 and S$24.90, depending on the model.

It also found that some of the trackers had mouldy straps and watch faces, adding that the two-year warranty for the remaining 35 per cent will expire by December 2021.

“Excess trackers not put to use by HPB had resulted in a significant sum of public funds wasted over the last five years, as the usability of these trackers would deteriorate over time due to the expiry of warranty and technology obsolescence,” it asserted.

Following AGO’s observation, HPB carried out a full stock account in January this year and uncovered the full stock showed that the number of excess trackers was 341,208, which amounted to S$5.39 million in total.

AGO also said HPB’s processes were “inadequate” in ensuring that the movement of fitness trackers was properly monitored and the trackers properly accounted for.

The receipt and distribution of the devices involved manual processes and multiple external parties such as suppliers and event organisers.

“However, there was no proper process to centrally monitor and account for the movement and stock of trackers. The records maintained were fragmented and incomplete, and there was no periodic reconciliation of the records with the stock on hand,” it noted.

There was also no documentary evidence on the scope or results of the annual stock checks carried out by HPB at an outsourced vendor’s warehouse.

AGO said that its test checks of the warehouse stock showed a shortfall of trackers compared to records maintained by HPB and the vendor.

Following AGO’s checks, HPB consolidated its records and found that there was an estimated shortfall of 17,909 fitness trackers worth S$720,000 in total.

“However, given the fragmented and incomplete records, there was inadequate assurance that this represented the actual shortfall,” AGO stated.

HSA’s total expenditure on small value purchases was substantial at S$8.02mil

AGO found that the Health Sciences Authority’s (HSA) total expenditure on small value purchases between 1 April 2018 to 30 June 2020 was substantial at S$8.02 million.

It noted that although HSA required items such as chemicals, laboratory devices and consumables – which totalling S$1.54 million – on a regular basis, it had been buying these items on an ad hoc basis via small value purchases instead of aggregating and procuring them through quotations or tenders.

For example, AGO said HSA had purchases S$0.35 million worth of chemicals, reagents and solvents from one vendor via 453 small value purchases over the 27-month period.

“As specified in the government instruction manual on procurement, small value purchases should be used only for ad hoc and low-value purchases,” it noted.

HDB distributed housing grants totalling S$405,000 to ineligible applicants

The report explained that CPF Housing Grants, which include Family Grant, Single Grant, Enhance CPF Housing Grant and Proximity Housing Grant, are distributed to eligible households for the purchase of HDB flats.

However, AGO conducted data analysis on resale applications with Family Grant and Single Grant from 1 April 2018 to 30 September 2020 and found out that 1,152 applicants “might not be eligible” for the grants.

“Of the 1,152 applicants, AGO test-checked 97 applicants and found that HDB had distributed Family Grants or Single Grants totalling (S$405,000) to 13 ineligible applicants (or 13.4 per cent),” it said, adding that these applicants failed to meet the eligibility criteria such as non-ownership of private property and income ceiling.

AGO also found lapses in the price reasonableness of single bids. It explained that four limited tenders (procurement value amounting to S$18.47million) of the 13 limited tenders awarded from 1 April 2017 to 31 March 2020 were “inadequate”.

For the three limited tenders (procurement value totalling to S$16.3million) with similar scope of works and requirements, AGO detected that although HDB had compared the single bid received by each tender against its own estimates, HDB failed to “take into account the volume of services which the tenderer was expected to handle”.

AGO noted that no assessments were done by HDB to determine any good reasons on why two of the single bids were priced much higher than the third bid.

As for the fourth limited tender, HDB issued one contractor tender documents with details like as-built drawings and technical requirements for enhancement works to roof fixtures, and has also asked a second contractor to provide a quotation in order to get a comparison quote.

However, it failed to provide the second contractor with any written specifications on the requirement of enhanced works, resulting in “inadequate assurance” of price quoted by the second contractor, which is used to assess the reasonableness of the price given by the single bid.

Irregularities in quotations

AGO test-check 194 quotations for 53 contract variations and one work order approved between July 2017 and November 2020, involving star items amounting to S$3.88 million under nine construction contracts.

Out of this, possible irregularities were noted in 40 quotations, which were for 16 contract variations and one works order involving star rate items amounting to a total of S$0.35 million.

HDB had appointed consultants to manage its construction contracts as well as to supervise contractors.

For contract variations and work orders involving star rate items, the consultants were supposed to assess the “price reasonableness” of the rates listed in the contractors’ invoices or quotations using different methods like verifying against one or more quotations from other sources, the report noted.

However, AGO checks found out that 40 quotations might have been “created or altered to give the impression that they were obtained from other suppliers and were reflective of fair market rates.

LTA delayed refunding advance payments amounted to S$1.65mil

AGO found 36 instances where the Land Transport Authority (LTA) had delayed refunding advance payments amounting to S$1.65 million to individuals or companies that requested works such as shifting or removal of streetlights, bus shelters or traffic lights.

The delays ranged from 11 months to 12.6 years after the works had been completed.

Following AGO’s audit, LTA refunded all 36 cases in March 2021. For 12 cases, the amount refunded was more than S$50,000 each with the highest refund amount at S$232,200.

AGO noted that the delays in refund arose due to the lack of coordination between LTA divisions, and a lack of monitoring of the advance payments received.

AGO flagged tendering issues by MPA

AGO carried out checks on a S$0.43 million tender for event and venue management services for a 2018 event organised by the Maritime and Port Authority of Singapore (MPA), and found the following lapses:

  • Discussions with a tenderer to make significant changes to its proposal and informing the tenderer to start work before the Tender Approving Authority (TAA) had decided on the tender award;
  • A significant error in the tender evaluation report

AGO noted that the MPA officer in charge had also engaged in detailed discussions with one tenderer that was later awarded the contract before TAA made a decision.

The MPA officer had also asked the tenderer to proceed with the fabrication of the props and assisted the tenderer to source for book alternative venues.

AGO also found that there were changes made to all four games and all four venues stated in the tenderer’s proposal, but these changes were not reflected in the Tender Evaluation Report (TER).

“Furthermore, no approval for contract variations was sought, nor were variation orders issued for the changes made to the four games and four venues that the tenderer was awarded for,” it noted.

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CPF Special, MediSave, and Retirement accounts’ interest rate rises to 4.14% for Q4 2024

The Central Provident Fund (CPF) Board and Housing and Development Board (HDB) announced that the interest rate for CPF Special, MediSave, and Retirement accounts will increase to 4.14% in Q4 2024, up from 4.08%. The 4% floor rate will be extended for another year, providing members with stability amid a volatile interest environment, the announcement stated.

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SINGAPORE: In a joint announcement on Friday (20 September), the Central Provident Fund (CPF) Board and the Housing and Development Board (HDB) revealed that the interest rate for CPF Special, MediSave, and Retirement accounts will rise to 4.14% for the fourth quarter of 2024, up from 4.08% in the previous quarter.

This increase, effective from October to December, comes as the pegged rate exceeds the established floor rate of 4%.

The government has also extended the 4% interest rate floor for these accounts for another year, valid from January 1 to December 31, 2025.

“This extension of the floor rate will continue to provide CPF members with certainty on the returns of their CPF savings amidst the volatile interest rate environment,” the announcement stated.

The interest rate for these accounts is tied to the average yield of 10-year Singapore Government Securities plus an additional 1%.

Meanwhile, the Ordinary Account (OA) interest rate will remain unchanged at 2.5% for the upcoming quarter, as its pegged rate is below the floor rate.

Additionally, the concessionary interest rate for HDB housing loans, set at 0.1% above the OA interest rate, will stay at 2.6%.

To further bolster retirement savings, CPF members will continue to earn extra interest.

Members below 55 years will receive an additional 1% on the first S$60,000 (approximately US$46,500) of their combined balances, capped at S$20,000 for the OA.

For those aged 55 and above, the extra interest comprises 2% on the first S$30,000, capped at S$20,000 for the OA, and 1% on the subsequent S$30,000.

Extra interest accrued on OA balances will be allocated to a member’s Special Account or Retirement Account.

For members above 55 who join CPF LIFE, the additional interest applies to their combined CPF balances, including savings utilized for CPF LIFE.

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US taxation authority to pursue wealthy tax evaders with advanced AI tools

The Internal Revenue Service (IRS) of United States has announced a comprehensive initiative aimed at aggressively pursuing individuals and entities that owe substantial amounts in overdue taxes.

Under the initiative, 1,600 millionaires and 75 large business partnerships are the primary focus of the IRS’s intensified “compliance efforts.”

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WASHINGTON, UNITED STATES: The Internal Revenue Service (IRS) announced last Friday (8 Sept), that it is embarking on an ambitious mission to aggressively target 1,600 millionaires and 75 large business partnerships that collectively owe hundreds of millions of dollars in overdue taxes.

IRS Commissioner Daniel Werfel revealed that with increased federal funding and the aid of cutting-edge artificial intelligence tools, the agency is poised to take robust action against affluent individuals who have been accused of evading their tax obligations.

During a call with reporters to provide a preview of the announcement, Commissioner Werfel expressed his frustration at the contrast between individuals who dutifully pay their taxes on time and those wealthy filers who, in his words, have “cut corners” when it comes to fulfilling their tax responsibilities.

“If you pay your taxes on time it should be particularly frustrating when you see that wealthy filers are not,” he said.

The IRS’s latest initiative targets 1,600 millionaires, each of whom owes a minimum of US$250,000 in back taxes, along with 75 large business partnerships boasting average assets of approximately US$10 billion.

These entities are now under the spotlight of the IRS’s renewed “compliance efforts.”

Werfel emphasised that a substantial hiring campaign and the implementation of artificial intelligence research tools, developed both by IRS personnel and contractors, will play pivotal roles in identifying and pursuing wealthy tax evaders.

This proactive approach by the IRS aims to highlight positive outcomes resulting from the increased funding it has received under President Joe Biden’s Democratic administration.

Notably, this move comes amid efforts by Republican members of Congress to reassess and potentially reduce the agency’s funding allocation.

IRS has introduced an extensive programme aimed at revitalisng fairness within the tax system

The IRS announced the groundbreaking move aimed at enhancing tax compliance and fairness, with a particular focus on high-income earners, partnerships, large corporations, and promoters who may be abusing the nation’s tax laws.

This initiative follows the allocation of funding under the Inflation Reduction Act (IRA) and a comprehensive review of enforcement strategies.

The new effort, which builds on the groundwork laid following last August’s IRA funding, will place increased attention on individuals with higher incomes and partnerships, both of which have experienced significant drops in audit rates over the past decade.

These changes will be facilitated through the implementation of advanced technology and Artificial Intelligence (AI) tools, empowering IRS compliance teams to more effectively detect tax evasion, identify emerging compliance challenges, and improve the selection of audit cases to prevent unnecessary “no-change” audits that burden taxpayers.

As part of the effort, the IRS will also ensure audit rates do not increase for those earning less than $400,000 a year.

Additionally, the agency will introduce new safeguards to protect those claiming the Earned Income Tax Credit (EITC).

The EITC is intended to assist workers with modest incomes, and despite recent years seeing high audit rates for EITC recipients, audit rates for individuals with higher incomes, partnerships, and those with complex tax situations have plummeted.

The IRS will also take measures to prevent unscrupulous tax preparers from exploiting individuals claiming these vital tax credits.

This move underscores the IRS’s commitment to fostering a fair and equitable tax system, ensuring that all taxpayers, regardless of income or complexity, are held to the same standards of compliance and accountability.

The initiative reflects a comprehensive approach to addressing disparities in tax enforcement and strengthening the integrity of the tax system for the benefit of all Americans.

“This new compliance push makes good on the promise of the Inflation Reduction Act to ensure the IRS holds our wealthiest filers accountable to pay the full amount of what they owe.

“The years of underfunding that predated the Inflation Reduction Act led to the lowest audit rate of wealthy filers in our history. I am committed to reversing this trend, making sure that new funding will mean more effective compliance efforts on the wealthy, while middle- and low-income filers will continue to see no change in historically low pre-IRA audit rates for years to come,”

“The nation relies on the IRS to collect funding for every critical government mission, from keeping our skies safe, our food safe and our homeland safe. It’s critical that the agency addresses fundamental gaps in tax compliance that have grown during the last decade,” Werfel said.

Major expansion in high-income/high wealth and partnership compliance work

Prioritisation of high-income cases: Under the High Wealth, High Balance Due Taxpayer Field Initiative, the IRS is intensifying efforts to address taxpayers with total positive income exceeding US$1 million and recognised tax debts of more than US$250,000.

Building on prior successes, which resulted in the collection of US$38 million from over 175 high-income earners, the IRS is allocating additional resources to focus on these high-end collection cases in Fiscal Year 2024.

The agency is proactively reaching out to approximately 1,600 taxpayers in this category who collectively owe substantial sums in taxes.

Expansion of pilot focused on largest partnerships leveraging Artificial Intelligence (AI): Recognising the complexity of tax issues in large partnerships, the IRS is expanding its Large Partnership Compliance (LPC) programme.

Leveraging cutting-edge Artificial Intelligence (AI) technology, the IRS is collaborating with experts in data science and tax enforcement to identify potential compliance risks in partnership tax, general income tax, accounting, and international tax.

By the end of the month, the IRS will initiate examinations of 75 of the largest partnerships in the United States, encompassing diverse industries such as hedge funds, real estate investment partnerships, publicly traded partnerships, large law firms, and more. These partnerships each possess assets exceeding US$10 billion on average.

Greater focus on partnership issues through compliance letters: The IRS has identified ongoing discrepancies in balance sheets within partnerships with assets exceeding US$10 million, indicating potential non-compliance.

Many taxpayers filing partnership returns are reporting discrepancies in the millions of dollars between year-end and year-beginning balances, often without attaching required explanations.

This effort aims to address balance sheet discrepancies swiftly, with an initial mailing of around 500 partnership notices set to begin in early October.

Depending on the response, the IRS will incorporate these cases into the audit process for further examination.

Priority areas for targeted compliance work in FY 2024

The IRS has launched numerous compliance efforts to address serious issues being seen. Some of these, like abusive micro-captive insurance arrangements and syndicated conservation easement abuses, have received extensive public attention. But much more work continues behind the scenes on other issues.

Among some of the additional priority areas the IRS will be focused on that will touch the wealthy evaders include:

Expanded work on digital assets: The IRS is continuing its expansion of efforts related to digital assets, encompassing initiatives such as the John Doe summons and the recent release of proposed broker reporting regulations.

The IRS’s Virtual Currency Compliance Campaign, which aims to ensure compliance with tax obligations related to digital currencies, will persist in the coming months.

An initial review has indicated a potential non-compliance rate of 75% among taxpayers identified through record production from digital currency exchanges.

The IRS anticipates the development of additional digital asset cases for further compliance efforts in early Fiscal Year 2024.

More scrutiny on FBAR violations: High-income taxpayers across various segments have been utilising foreign bank accounts to avoid disclosure and related tax obligations.

US individuals with a financial interest in foreign financial accounts exceeding US$10,000 at any point in the year are required to file a Report of Foreign Bank and Financial Accounts (FBAR).

The IRS’s analysis of multi-year filing patterns has revealed hundreds of potential FBAR non-filers with average account balances exceeding US$1.4 million. In response, the IRS plans to audit the most egregious potential non-filer FBAR cases in Fiscal Year 2024.

Labour brokers: The IRS has identified instances in which construction contractors are making payments to apparent subcontractors via Form 1099-MISC/1099-NEC, yet these subcontractors are, in fact, “shell” companies lacking a legitimate business relationship with the contractor.

Funds paid to these shell companies are routed through Money Service Businesses or accounts associated with the shell company before being returned to the original contractor. This scheme has been observed in states like Texas and Florida.

The IRS is expanding its attention in this area, conducting civil audits and launching criminal investigations to address non-compliance.

This effort is aimed at improving overall compliance, ensuring proper employment tax withholding for vulnerable workers, and creating a fairer playing field for contractors adhering to the rules.

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