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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
IRS Issues Audit Technique Guide for Entertainment Industry
November 23rd, 2015
In connection with the examination (auditing) process, the IRS has been preparing Audit Techniques Guides (ATGs) intended to assist IRS examiners during audits by providing insight into issues and accounting methods unique to specific industries. ATG…
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Categories: IRS Audits
New IRS Guidelines Limiting FBAR Penalties
November 20th, 2015
Penalties for failure to file required FBAR reports disclosing foreign financial accounts for taxpayers who do not participate in one of the available Offshore Voluntary Disclosure Programs are severe. Civil penalties for non-willful failure to file,…
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