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Tax Lawyers USA - Recent Legal Articles
- Willfulness and the Civil FBAR Penalty
In 2008, when it was revealed that wealthy individuals around the world were utilizing accounts and trusts in Liechtenstein to evade taxes, the United States initiated a coordinated effort with foreign governments to combat tax evasion through the use of offshore trusts and accounts. The U.S. Department of Justice (DOJ) has since launched criminal investigations of several foreign banks, many of which are ongoing.
- IRS Changing Terms for Offshore Account Holders
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.
- U.S. District Court Upholds Multiple Willful FBAR Penalties Against Taxpayer
In a case that has raised eyebrows in the tax community, a jury in the Southern District of Florida has sustained the IRS’s assessment of multiple willful FBAR penalties against an American business man and bank director.
- 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
- U.S. to Ease Initial Enforcement of FATCA (Foreign Account Tax Compliance Act)
With FATCA set to take effect on July 1, financial institutions around the world have been lobbying to delay implementation of the law, citing concerns about costs and potential disruptions to global markets.
- The Shifting Landscape of the OVDP Opt-Out
Since the IRS announced the 2009 Offshore Voluntary Disclosure Program (OVDP) over five years ago, our firm has been assisting taxpayers submit accurate and complete disclosures in accordance with the program guidelines and procedures. The evolution of the OVDP through the 2011 and 2012 programs has brought a longer look-back period, steeper penalties, and more insight into IRS positions and procedures at different points in the program.
- FBAR and FATCA – Two Abbreviations That Can Wrap You Around the IRS Axle
FBAR and FATCA are two important abbreviations for those who have overseas financial interests. Failure to file the FBAR report, in view of the IRS’s continuing application of FATCA, can get you into what old military veterans used to call FUBAR.
- Deconstructing the “Act of Production” Doctrine
Tax cases are document-intensive cases. As any white-collar criminal defense attorney knows all too well, summonses and grand jury subpoenas routinely seek documents. And there is a good reason why. If the government cannot get the requested documents, it often cannot make a case. It is for this reason that the seminal issue in document production cases is whether the taxpayer has a Fifth Amendment privilege with respect to documents that he possesses.
- The Rules Governing Taxation of Foreign Nationals
Below are the rules governing taxation of foreign nationals.