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The definitions of words in the U.S. tax code can be the difference between criminal convictions and financial consequences. Most taxpayers would assume that one word in that code would have one meaning. But when it comes to the definitions of willfu…
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The difference between a willful and non-willful FBAR penalty against a U.S. taxpayer can be thousands, and sometimes millions of dollars. But how can the IRS know what was going on in your head, and whether your failure to file was on purpose? A rec…
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A recent federal court tax fraud lawsuit against a woman and her deceased husband’s estate has set a new record for FBAR penalties exceeding over $119.6 million. Find out what the IRS says she and her husband did to deserve such a steep penalty.
Hu…
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Where does an entirely virtual financial institution exist: on your phone, in a server-farm somewhere? Could the location of the founding company turn your Bitcoin wallet into a foreign financial institution? If so, you may need to report cryptocurre…
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Preparing your own tax returns is hard enough when you are a regular employee with standard deductions. But what about when some of your currency only exists digitally? What do you need to know about reporting cryptocurrency on your tax returns? Will…
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When taxpayers with foreign financial accounts take advantage of the IRS voluntary disclosure practice, they know that mistakes have been made, and that penalties will follow. But they probably don’t think of themselves as “tax criminals”. Th…
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When tax attorneys came together at the New York University Tax Controversy Forum, everyone was talking about recent cases over the upper limit of willful FBAR penalties on a single account. But for one speaker, the question was which was worse: bein…
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If you are a foreign resident but a U.S. taxpayer, it can be especially difficult to find the right way to challenge an unfair tax assessment. You may question if internal IRS appeals are enough, or whether you have the right to refuse payment and su…
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When you open a new financial account overseas, it often is technically more than one account. You may have both checking and savings accounts at a foreign bank. Or your investments may be divided into different accounts with different investment str…
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When Motown writer Edward J. Holland, Jr., owed the IRS nearly $20 million, the agency took some extreme steps to collect on the tax debt. It even seized 100% of his social security payments. Find out how the IRS could do that, and whether you need t…
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