Tax Planning Lawyers in the USA


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Tax Planning Lawyers USA - Recent Legal Articles

  • IRS Changing Terms for Offshore Account Holders
      by Brown, PC

    U.S. taxpayers hiding assets abroad should take note of the Internal Revenue Service’s plan to sharply increase penalties for such acts, while those who unintentionally fail to disclose offshore accounts will experience much more leniency.

  • Extra! Extra! Read All About It! IRS Commissioner Announces That Changes Are In the Offing For OVDP 2012

    On June 3, 2014 the new IRS Commissioner, John A. Koskinen, gave a speech before the International Business - OECD International Tax Conference. His speech covered the history of the offshore enforcement initiative since the UBS debacle in 2009. His remarks acknowledge what most professionals in the tax community have recognized since the inception: that OVDP needs more tweaking in order to meet the overall goals of enforcement and fairness.

  • Alphabet Soup for Installment Agreements

    What is an installment agreement? An installment agreement is an option for those who cannot pay their entire tax bills by the due date. It allows taxpayers to pay the amount due over a period of time

  • Lifting the Veil on the Civil FBAR Penalty

    It should come as no surprise that the IRS has authority to assess FBAR civil penalties. However, what might come as a surprise is that an FBAR violation doesn’t automatically mean that a penalty will be asserted. Why not?

  • No Laughing Matter: The Criminal Consequences of Failing to Report Foreign Bank Accounts

    United States citizens, residents and other persons must annually report their direct or indirect financial interest in, or signature authority over, a financial account that is maintained with a financial institution located in a foreign country if, for any calendar year, the aggregate value of all foreign accounts exceeded $ 10,000 at any time during the year.

  • Liens and Levies Make the IRS a Collection Agency on Steroids

    Sometimes the problem with “food for thought” is that it can almost choke you with its stark simplicity. Take our tax system, for example. The federal government prints our money, regulates the places where we keep it and has vast powers to take it away from us if we don’t give them their cut.

  • IRS Due Process Collections - Placing a Velvet Glove on the Wrecking Ball

    Due process is, according to Black’s Law Dictionary, “a course of legal proceedings … which have been established … for the enforcement and protection of private rights.” Anyone facing an IRS federal tax lien or levy has already experienced the preliminary due process following the IRS determination that more taxes are owed.

  • Think You Got Game? Try Solving a Criminal Tax Problem

    While reading can aid in learning, there is no substitute for doing. Reading about what steps should be taken to solve a tax problem is no different than reading about how to ride a bicycle. In the same way that the only way to learn how to ride a bicycle is by experiencing it firsthand – i.e., by physically getting on it (and perhaps falling off it more than once) – the only way to become proficient at solving tax problems is by trudging through a multitude of hypotheticals.

  • Failing to File a Tax Return and that “Wascally” Little Word (not "Wabbit") Called Willfulness

    Nary a day goes by that a client doesn’t ask me the question, “Why am I being charged criminally with failing to file my tax returns? Lots of people get behind on their taxes and fail to file their returns for a few years, but they are not prosecuted. Why me?”

  • Home Sweet Home for International Tax Collection

    Recently, I received a panicked call from a client being detained at a major metropolitan airport. The client, a nonresident U.S. taxpayer, owed money to the Internal Revenue Service. Upon investigation, I learned who was responsible for detaining him: none other than the IRS. Under what authority? A two-year-old program designed to target nonresident delinquent taxpayers who travel to and from the United States.


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