The IRS can revoke your passport
If you do not pay your taxes, the IRS may revoke your passport. As the National Taxpayer Advocate (NTA) Nina E. Olson has recently pointed out in her blog, when a taxpayer is notified of such pending
New Jersey Enacts Tax Amnesty Bill
Enacted legislation requires the New Jersey Division of Taxation to establish a 90-day state tax amnesty period that ends no later than January 15, 2019. The Legislature had previously passed a bill requiring a six-month
The TCJA and the Future of American Taxpayers
Our article on the new tax law was published today by the American Bar Association below… https://www.americanbar.org/groups/gpsolo/publications/gpsolo_ereport/2018/june-2018/tcja-future-american-taxpayers.html The TCJA and the Future of American Taxpayers Vol. 7, No. 11 Parag Patel and Anannya Tripathy Parag Patel,
Federal District Court Holds that FBAR Penalties in Excess of $100,000 is Unlawful
Recently, the U.S. District Court for the Western District of Texas in U.S. v. Colliot, determined that an individual who repeatedly failed to timely file Form TD F 90-22.1, Report of Foreign Bank and Financial Accounts, commonly
2018 ABA COMMENTS ON THE OFFSHORE VOLUNTARY DISCLOSURE PROGRAM AND THE STREAMLINED PROGRAMS
We are members of the American Bar Association Section of Taxation, which on May 2, 2018 submitted comments to the IRS on the IRS Offshore Voluntary Disclosure Program (“OVDP”), the Streamlined Domestic Offshore Program (“SDOP”), and the
New FBAR Court Case Makes it Easier for Taxpayers to be Deemed Willful
There is a debate as to the “burden of proof” that must be met by the Internal Revenue Service (IRS) in asserting that an FBAR violation was “willful”. This is significant because those who willfully
IRS reminds those with foreign assets about U.S. tax obligations
The IRS again reminded taxpayers yesterday about their reporting obligations for foreign assets and income. The reminder again represents the IRS’ targeted enforcement of tax laws for reporting obligations for foreign assets and income. Taxpayers should take
Denied access to or withdrew from the IRS Offshore Voluntary Disclosure Program (OVDP)?
This year taxpayers who either were denied access to or withdrew from the IRS Offshore Voluntary Disclosure Program (OVDP) have been receiving Letter 5935 (HERE) from the IRS notifying them that they need to come into
Run to the Door: IRS Terminates Offshore Voluntary Disclosure Program (OVDP) effective September 28, 2018
IRS Issue Number: IR-2018-52 IRS to end offshore voluntary disclosure program; Taxpayers with undisclosed foreign assets urged to come forward now WASHINGTON – The Internal Revenue Service today announced it will begin to ramp down the
New Unreported Offshore Assets case: Bad facts leads to bad results
A resident of Connecticut who was originally from Korea has been hit with a record civil penalty of $14M, a six month prison sentence, and a fine of $100,000 for failing to report Swiss bank
FBAR statute of limitations court case ruling
In its first decision of 2018, the US Tax Court considered whether the six-year statute of limitations in Code Section 6501(e)(1)(A)(ii) applied to a taxpayer who failed to file Foreign Bank Account Reporting, or FBAR
The 65-Day Rule: What Every Trustee Should Know about Taxes
Happy New Year! With the close of the calendar year behind us, tax season is just beginning for individuals and many entities. If you are serving as the trustee of a complex trust, however, it’s