April 15 may be known as Tax Day, but every year, millions of taxpayers file tax extension forms to request more time to complete their tax returns. Many of those taxpayers don’t file the forms themselves. Instead, they rely on accountants to e-fil…
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What happens when a court decides the IRS miscalculated willful FBAR penalties? Will the penalty be forgiven? Is it the court’s job to fix the math errors, or should it remand the matter to the IRS to recalculate? And could that miscalculation actu…
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Whenever the IRS issues an assessment, it starts a clock. Unless taxpayers work quickly to address the issue, they will begin to accrue penalties and interest on that assessment. But what happens if you take the IRS to court over improper FBAR penalt…
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These days, many U.S. taxpayers have a side gig they use to supplement their income and pursue their passions. Sometimes, these activities can come with significant expenses. You may wonder whether creating a business entity will provide tax relief.…
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When family money is passed down through the generations, it isn’t always clear who owns the accounts, or who is required to disclose them to the IRS. A recent case from the Federal Court of Claims considers whether an undocumented, informal trust…
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Every year, millions of Americans file their taxes using TurboTax or another commercial tax prep software. The hope is that these programs will make sure their taxes are done correctly and avoid penalties or even an IRS audit. However, one recent cas…
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A trust can be a useful wealth management tool to reduce tax obligations, and ensure beneficiaries receive their intended assets. However, when that trust is held overseas, the IRS requires extra tax returns from both owners and beneficiaries to make…
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The question of just how expensive a willful penalty for failing to report foreign financial accounts has been making its way through the federal court systems. Now, the Second Circuit has issued a split opinion that shows just how divided judges are…
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Can the government restrict your ability to travel overseas if you don’t pay your taxes? Is the 2015 FAST Act’s passport certification process constitutional? One doctor challenged the law, but he may have filed his lawsuit a bit too soon. 20 Yea…
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Why would you file a lawsuit against the IRS just to turn around and ask the District Court to dismiss it? A combination of impatience, new precedent, and personality changes left a Plaintiff looking for a way out of the Federal Court of Claims. Inte…
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