Even if Congress acts to avoid the “Fiscal Cliff,” uncertainty about the future of the gift and estate tax laws will continue. Despite this uncertainty, meaningful estate planning goals can be achieved. Estate planning is
I just returned from the American Bar Association Section of Taxation’s annual National Institute on Criminal Tax Fraud in Las Vegas. A topic of discussion was the relatively new New Streamlined Filing Compliance Procedures for
Over the past several years our law firm has counseled hundreds of non-compliant U.S. taxpayers in the exploration of their legal options with respect to the Offshore Voluntary Disclosure Initiative programs. As a result, we
Despite the election results, taxes are going up! Although major tax law changes are set to take place in 2013, there are opportunities for high net worth individuals. Below are a few planning opportunities. Tax Provisions
Unless Congress acts quickly, taxes are going up! Although major tax law changes are set to take place in 2013, there are some planning opportunities for business owners: Tax Provisions Which May Impact Planning Opportunities ■
To help appreciate the planning opportunities individuals may have between now and year end, we have prepared a summary of the key tax law provisions affecting high income individuals. Tax Provisions Which May Impact Planning
Unless Congress acts quickly, taxes are going up! Although major tax law changes are set to take place in 2013, uncertainty makes it hard for families and businesses alike to plan ahead. Below are the expected
The Department of Justice continues to prosecute cases involving United States taxpayers who have failed to report their interests in offshore accounts. Most of the cases are for large offshore accounts, but they provide good guidance
When the IRS receives payment with amended tax returns for taxes, interest and penalties, the IRS may misapply the payment. This results in IRS notices. Reminiscent of the mistakes of the 2009 OVDP, the IRS
While opting out of the OVDI or OVDP amnesty programs may result in a reduction of penalties that may otherwise be assessed, the taxpayer needs to carefully weigh the numerous consequences before doing so. Responsible
FATCA was enacted in 2010 by Congress to target non-compliance by U.S. taxpayers using foreign accounts. FATCA requires foreign financial institutions (FFIs) to report to the IRS information about financial accounts held by U.S. taxpayers,
The current gift tax exclusion is scheduled to expire at midnight on December 31, 2012, bringing to an end the highest exemptions ever seen. Under current law for 2012, each person has the ability to
