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The Strange Case of U.S. v. Hughes: Willful and Non-Willful (at the Same Time?)

Search Results for: https://www.galaxus.ch/en/sector/showdiscussion/someone-hacked-my-snapchat-account-visit-kunghaccom-k6tz4ggc-226532

The Strange Case of U.S. v. Hughes: Willful and Non-Willful (at the Same Time?)

12 January, 2022

...Limited which was solely owned by Hughes. Ms. Hughes had a financial interest in, and signature authority over the two entities’ bank accounts for the following years. Hughes had to...

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How to Avoid Criminal Prosecution Through Voluntary Disclosure

7 January, 2022

...and the Taxpayer must then cooperate with the examiner in all aspects of providing documents and information.   To learn more about the updated Voluntary Disclosure Program go to: https://patellawoffices.com/blog/planning-for-tax-minimization/irs-updated-voluntary-disclosure-practice-is-a-game-changer/ ...

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All the Many FBAR Late Filing Procedures

2 January, 2022

The FBAR or Foreign Bank and Financial Account Reporting or FinCen Form 114 is a form which many U.S. taxpayers are unaware and unfamiliar with and thus many of them...

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Do You Have to Pay US Taxes on Foreign Inheritance?

1 December, 2021

...like interest earned in a U.S. bank account. Foreign Investment Accounts (Stocks, ETFs, Mutual Funds, and other pooled investments) – Foreign investment accounts and funds require more complex U.S. tax...

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Watered-Down Build Back Better (BBB) For High-Income Taxpayers

21 November, 2021

...that are often utilized when valuing an interest in an entity that holds non-business assets; The imposition of investment restrictions on IRAs that would prevent retirement accounts from holding certain...

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FBAR Deadline Extended to December 31, 2021

7 October, 2021

The Financial Crimes Enforcement Network (FinCEN) today issued a notice extending the filing date of Reports of Foreign Bank and Financial Account (FBARs) for victims of recent natural disasters, including...

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Pandora’s Box Has Opened: Pandora Papers

4 October, 2021

...B asks about the existence of foreign accounts, such as bank and securities accounts, and usually requires U.S. citizens to report the country in which each account is located. Penalties...

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An Ill-advised IRS Streamlined Filing Compliance Procedure Filing

25 September, 2021

...several years, Gyetvay allegedly took steps to conceal his ownership and control over the foreign accounts and associated assets, such as removing himself and making his then-wife, a Russian citizen,...

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New IRS procedures for Streamlined Filing Compliance Procedures for 2017 transition tax filers

31 August, 2021

...complex Streamlined Filing Compliance Procedures even more complex. Given the timing of this announcement, it is possible that the IRS realized that filers may have been excluding 2017 and the...

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FBAR Deadline Automatic Extension

18 August, 2021

...year, each annual FBAR must be filed with FInCen by April 15th. This change to an April 15th FBAR filing date was designed to match the FBAR filing date with...

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Solution: Streamlined Domestic Offshore Procedures

14 August, 2021

...of non-willful behavior could include having a small account, especially in comparison to the taxpayer’s other assets; an account on which no U.S. tax is due; a foreign government-sponsored savings...

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Consequences of Filing False Streamlined Filings

19 June, 2021

...penalty. However, to be eligible for the SDOP program, the Taxpayer in failing to report foreign financial accounts must have been due to non-willful conduct. It is illegal for a...

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