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Federal Court Imposed Penalties for Reckless FBAR Violations
January 27th, 2017
The difference between willful and non-willful FBAR violations amount to hundreds of thousands of dollars. But what counts as willfulness can sometimes be unclear. A recent federal district court decision says even reckless taxpayers could face stiff…
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IRS Commissioner Pushes for OVDP Program to Continue
January 12th, 2017
Any presidential election brings with it the chance for changes to tax laws and enforcement priorities. IRS Commissioner John Koskinen explains that, at least through November 2017, the Offshore Voluntary Disclosure Program (OVDP) will continue. Many…
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Categories: OVDP
Tax Shortcuts Can Lead to Criminal Consequences
December 30th, 2016
No one wants to pay more than they have to in taxes. But taking tax shortcuts can cause big problems when the IRS and the Justice Department get involved. Depending on the size, length of time, and severity of the tax fraud, you could even face crimi…
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Categories: Tax / IRS Penalties
Credit Suisse Freezes Accounts to Find Non-Reporting U.S. Taxpayers
December 20th, 2016
If you are a U.S. taxpayer with accounts over seas, you may feel safe not reporting that income. You might assume there is no way the IRS will know. If so, recent activity by the Swiss bank Credit Suisse should give you food for thought. The Foreign…
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OVDP or Streamlined: Which Voluntary Disclosure Procedure Should You Use?
November 29th, 2016
The IRS recently encouraged U.S. taxpayers to come clean about unreported foreign financial assets and income. The agency offered up two voluntary disclosure procedures to save non-compliant taxpayers from steep penalties and criminal prosecutions. B…
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Get Your Offshore Account Voluntary Disclosures Resolved Before Year End
November 18th, 2016
If you are one of the thousands of American taxpayers with offshore financial accounts, the idea of not being in compliance with IRS reporting requirements may make your hair stand on end. You don’t have to live in fear of an audit. Find out ho…
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How Can I Prove My Failure to File Was Non-Willful?
October 21st, 2016
You have just discovered that you were required to file disclosures related to foreign financial accounts in your possession. You know that you weren’t trying to avoid the IRS, but how do you communicate that your failure to file was non-willfu…
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Categories: OVDP
IRS Guidance Makes FBAR Penalties More Predictable
October 14th, 2016
When you discover that the IRS is investigating you for failing to report foreign financial accounts it can be intimidating. If you are facing the possibilities of FBAR penalties and criminal imprisonment, Your first question will likely be, “W…
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Pending Federal Legislation Would Authorize Revocation or Non-Renewal of Passports of U.S. Expatriates Who Owe $50,000 in Taxes
December 5th, 2015
The House and Senate have passed separate versions of a highway funding bill (H.R. 3763: Surface Transportation Reauthorization and Reform Act of 2015; S.808 – Surface Transportation Board Reauthorization Act of 2015) which must be reconciled b…
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Categories: Tax News
Bipartisan Budget Act of 2015 Repeals TEFRA Partnership Audit Rules in Effect Since 1982
November 30th, 2015
Partnerships – including partnerships with 100 or more partners – are among the fastest growing types of business entities in the United States today. A provision of the Bipartisan Budget Act of 2015 (“BBA”), which had the salutary ef…
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Categories: Tax News
