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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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Being a Motown artist behind famous songs like “Stop in the Name of Love” and “You Keep Me Hangin’ On” doesn’t excuse not paying millions of dollars in tax debt.
But did the IRS go too far when it placed a levy on royalties owed to Gold F…
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From the Court of Federal Claims to District Courts across the country, it seems everyone has an opinion on whether an old IRS regulation caps willful FBAR penalty maximums well below the amounts authorized in the statute. Now a new decision further…
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There has been a lot of news lately about the IRS certifying taxpayers to the State Department for seriously delinquent tax debt. Certification means a taxpayer’s passport will not be renewed and could be revoked. If you are behind on your taxes, d…
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Enforcement at the IRS is getting tighter. Now that the Offshore Voluntary Disclosure Program is closed, taxpayers with foreign financial accounts are facing the possibility of higher penalties and tighter scrutiny of their offshore assets. One metho…
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Receiving a notice from the IRS is always stressful. When that document tells you that your passport could be affected, it can make you nervous to exercise your constitutional right to international travel. New changes to the U.S. Tax Court’s rules…
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If you have been assessed a civil penalty for willful FBAR violations, you may be wondering whether the IRS has the final say. Find out how to challenge a penalty for willful FBAR violations, and how the courts will decide whether or not you have to…
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