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U.S. Constitution

IRS Says FBAR Penalty Is Not a Fine Under Eighth Amendment

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
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Swiss bank

Mirelis Customers Face OVDP Fines After Non-Prosecution Settlement

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
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IRS Agent Showing Red Card for Willful Violation of FBAR Reporting Requirements

What Do Willful Violations of FBAR Reporting Requirements Look Like?

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
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U.S. Passports

What to Do if You are Certified for Passport Revocation by the IRS

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
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Categories: Tax / IRS Penalties
US Passport

National Taxpayer Advocate Calls Passport Revocation for Unpaid Taxes Unconstitutional

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
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Categories: Tax / IRS Penalties
Using Smartphone as Calculator - Determining PFIC Excess Distribution Interest Penalties

PFIC 101: How to Avoid PFIC Excess Distribution Interest Penalties

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
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Photo of Woman Pointing with Pen to PFIC stock interests Line Item on Printout

PFIC 101: How to Tell if You Have PFIC Stock Interests

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
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PFIC - Financial Data on Global Map

PFIC 101: Reporting PFIC Tax Obligations for Foreign Stockholders

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
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Report of Passive Foreign Investment Company

​PFIC 101: What is a Passive Foreign Investment Company?

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
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Options Sign

The OVDP Is Ending. What Now?

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
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Categories: OVDP

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