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When a taxpayer falls seriously behind in paying tax obligations, they may fall subject to IRS passport revocation procedures used to collect the outstanding tax liabilities. But does the IRS blocking a taxpayer’s ability to get or renew a passport… Read More

When taxpayers hire accountants to help prepare their tax returns, they expect it to be done right, and to save them from audits. But sometimes the quality of that product is limited by the information the taxpayers themselves provide. A recent Unite… Read More

International sanctions made it hard for two Irani immigrants to transfer proceeds from the sale of their home. But the U.S. District Court in Oregon said that what they did next created FBAR problems resulting in willful FBAR penalties that no jury… Read More

Anything can cause you to miss a deadline, from illness to mailing issues. But the IRS doesn’t tend to excuse those delays. This can raise the question, what happens if your tax deficiency petition is filed late? Can you ask for an extension? Can t… Read More

Most taxpayers assume that once they submit a tax return for the year, they will have satisfied the tax reporting rules, and their duty to the IRS is done. For those with more complicated tax situations, they may rely on a tax preparer to make sure e… Read More

If you are facing criminal FBAR charges for failing to disclose your foreign financial accounts, you and your tax attorney may need to get creative in crafting your defense. But as one recent criminal tax case from Massachusetts shows, creativity doe… Read More

Accounts and organizations created under foreign laws do not always fit easily into the Internal Revenue Code’s models, but that does not excuse the founders from following IRS trust reporting requirements. Understanding what counts as a foreign tr… Read More

When the IRS imposes penalties, it can sometimes seem as though the number is plucked from the air. But when an FBAR penalty case goes to trial, the IRS is required to prove the amount of its penalty complied with the law. However, a now-familiar cas… Read More