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Pre-Immigration Income Tax Planning

6 February, 2013

Since the United States has some of the highest tax rates and most complex tax rules in the world pre-immigration tax planning is very important (but rarely done). Various actions that resident and nonresident aliens

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National Taxpayer Advocate Identifies OVDP Program as a Serious Problem

1 February, 2013

On January 17 that National Taxpayer Advocate Nina Olson recently issued her 2012 Annual Report to Congress calling on Congress to simplify the Tax Code. In her report, Olson questioned the “one-size-fits-all” approach of the

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HSBC Payment of Largest Penalty and FATCA Encourages Taxpayers to Disclose

30 January, 2013

Last month, HSBC Holdings agreed to pay $1.92 billion in fines to U.S. authorities, which is the largest collective settlement in the Treasury Department’s history. The penalty assessment was based upon HSBC’s conduct in violation

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Important Provisions of the American Taxpayer Relief Act of 2012

25 January, 2013

On January 1, 2013, Congress passed the American Taxpayer Relief Act of 2012 (“Act”) which was signed into law on January 2, 2013. While certain provisions of the Act are considered to be “permanent”, an

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Bank Leumi: Another Foreign Bank Recommends the IRS Voluntary Disclosure Program

23 January, 2013

Bank Leumi is urging its U.S. clients to disclose information about their accounts to U.S. authorities investigating Leumi and many other foreign banks over possible tax avoidance by Americans. In a December 16 letter Leumi

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Another HSBC Customer Likely Going to Jail

11 January, 2013

Last week a New Jersey client of HSBC Holdings Plc (HSBA) pleaded guilty to charges that he hid as much as $4.7 million through Swiss and Indian accounts not declared to the U.S. Internal Revenue

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Off the Cliff Commentary About the New 2013 Tax Law

2 January, 2013

As predicted, Congress waited until the last minute to make a deal, technically after we plunged off the fiscal cliff to pass a new tax law. The new 2013 tax law, in summary, is below

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Uncertainty About The Future Of The Gift And Estate Tax Laws Will Continue

26 December, 2012

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

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New Comments of the IRS’ New Streamlined Filing Compliance Procedures for Non-Resident Non-Filer U.S. Taxpayers

22 December, 2012

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

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Benefits and consequences of entering or failing to enter the Offshore Voluntary Disclosure Initiative program

29 November, 2012

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

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Tax Planning Opportunities for High Net Worth Individuals

7 November, 2012

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

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Tax Planning Opportunities for Business Owners

3 November, 2012

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 ■      

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