Schedule Case Assessment
(215) 854-6310
Experienced · Local · Affordable
Willful FBAR penalties can quickly add up to hundreds of thousands of dollars. But are those penalties an unconstitutional fine under the Eighth Amendment? In a recent filing in the United States Court of Federal Claims, the government said the amoun…
Read More
Customers of the Swiss financial and asset management company Mirelis Holdings, SA, may have known about changes happening at the company in recent years. But what they may not have realized is that a recent non-prosecution settlement between the fir…
Read More
The difference between penalties for willful violations of FBAR reporting requirements and non-willful violations could be hundreds of thousands of dollars, federal criminal charges, and prison time. But it can be hard for taxpayers to know what to e…
Read More
The IRS has started to send certification of individual taxpayers with seriously delinquent tax debt to the State Department for passport consequences under the FAST Act. Your options to appeal this determination are limited. Know what to look for an…
Read More
Can the IRS take away your right to travel without advanced notice? The National Taxpayer Advocate says the passport revocation program created by Congress in 2016 — which authorizes passport revocation for unpaid taxes — may be unconstitutional…
Read More
Once U.S. taxpayers identify passive foreign investment company assets in their portfolio, the next logical step is to minimize the tax consequences connected to those assets. At the top of the list is finding a way to avoid PFIC excess distribution…
Read More
It may seem easy to know whether a U.S. taxpayer has stock interests overseas. You may think that you will cross that bridge if and when you decide to invest in a foreign investment company. But you may have PFIC stock interests you don’t recog…
Read More
When U.S. taxpayers own stock in foreign mutual funds and other investment companies, they may know the income from those assets need to be reported to the IRS. They may even know they can be taxed on that foreign income. But for many U.S. shareholde…
Read More
When U.S. taxpayers own or have interest in foreign assets overseas, it can raise reporting and tax consequences they don’t expect. FBARs and foreign asset reporting requirements can leave taxpayers worrying about what other legal obligations they…
Read More
Since the IRS announced that the OVDP is ending on March 13, 2018, you may be wondering what you can do to limit your exposure to audits or tax penalties for unreported financial assets overseas. Here are some options to consider with your tax attorn…
Read More
© 2018 Joseph R. Viola
View Our Disclaimer | Privacy Policy
Law Firm Website Design by The Modern Firm
